CA6: Affidavit for SW failed both PC and nexus, but GFE applied: affidavit was detailed and 62 pages

The affidavit for the search warrant here failed to show both probable cause and nexus, and the court details why. However, the 62 page detailed affidavit detailing the whole investigation was not bare bones by any means, and the good faith exception applies. United States v. Smith, 2018 U.S. App. LEXIS 30963 (6th Cir. Nov. 1, 2018):

In contrast, here, the 62-page affidavit contains evidence of Fitzgerald’s involvement in ongoing drug activity based on confidential informant reports and a year of wiretapped conversations and other surveillance of suspected co-conspirators. For example, the confidential informant claimed to speak regularly with Fitzgerald’s half-sister, co-defendant Anderson, about the conspiracy and specifically described Fitzgerald’s role as the FedEx deliverer. Magistrate judges authorized wiretaps on Fitzgerald’s and Walker’s cell phones and a tracker on Walker’s vehicle. Experienced officers interpreted the suspects’ cryptic phone and text conversations to refer to drug deliveries and payments. On days tapped phone calls led officers to believe Fitzgerald and Walker planned to meet, surveillance of Anderson’s residence showed Walker arriving with Pelican cases.

There is, moreover, no evidence in the record that officers did not rely on this warrant in good faith or that they applied for the warrant knowing the information within it was false. Similarly, we have no evidence that the magistrate “wholly abandoned [her] judicial role.” Leon, 468 U.S. at 923. The warrant is not “so lacking in indicia of probable cause that a belief in its existence is objectively unreasonable.” Laughton, 409 F.3d at 748. In light of the entire record, we do not find it objectively unreasonable for an officer to believe that the affidavit established probable cause to search Fitzgerald’s residence. We therefore conclude that the good faith exception applies and affirm the district court’s denial of Fitzgerald’s motion to suppress.