“Deputy Tucker’s affidavit established a minimally sufficient nexus between the criminal activity and the place to be searched.” Therefore, the affidavit shows probable cause. “The warrant was not based on an affidavit that ‘merely states suspicions, beliefs, or conclusions.’ Roach, 582 F.3d at 1204-05. It adequately linked the Pair’s criminal activity to the place to be searched.” The affidavit here was stronger than approved in another case. United States v. Chambers, 2018 U.S. App. LEXIS 4787 (10th Cir. Feb. 27, 2018).* Not a ringing endorsement, but the good faith exception in SCOTUS just requires minimal effort.*
After the suppression hearing and before the appellate brief was due, the state supreme court abandoned the more rigid Aguilar-Spinelli test for informant hearsay. The CI’s basis of knowledge is still important. On the totality, there was probable cause. State v. Ferguson, 2018 Tenn. Crim. App. LEXIS 149 (Feb. 27, 2018).*
* Good enough for government work?