W.D.Mo.: For purposes of entry on an arrest warrant, officers can reasonably believe def had two addresses

“Under the facts of this case, the Court concludes that law enforcement agents had the requisite reasonable belief that Sparks was residing at 6825 Walrond Avenue and/or 5501 Smart Avenue and was present at the addresses at the time of the attempted execution of the arrest warrant. The Court sees no contradiction or fatal inconsistency with officers having a “reason to believe” that a suspect may reside — and be found — at two different addresses. Here, officers had satisfactory contemporary operative facts that pointed to Sparks residing at both addresses.” United States v. Sparks, 2020 U.S. Dist. LEXIS 13845 (W.D. Mo. Jan. 7, 2020).

The officers’ summary of a report wasn’t as detailed as the report, but it wasn’t misleading either. Therefore, a Franks hearing isn’t required. United States v. Sheehan, 2020 U.S. Dist. LEXIS 13781 (D. Mass. Jan. 28, 2020).*

This entry was posted in Arrest or entry on arrest, Franks doctrine. Bookmark the permalink.

Comments are closed.