E.D.Mich.: CI’s information showed almost nothing as to one property for SW, so no PC nor GFE

The affidavit for the warrant for one particular address in this case fails to even minimally show probable cause. “Here, there was not enough information in the affidavit to allow a reasonable officer to conclude that there was sufficient ‘ongoing drug activity’ to justify a search of Defendant Harden’s residence on Shadowlawn based just on that activity. Nor was there anything establishing a ‘minimally sufficient nexus’ between the alleged drug dealing and the Shadowlawn residence that justified officers’ reliance on the warrant: the anonymous tips make no mention of the Shadowlawn residence at all, and the affidavit identifies only a single ‘short stay’ at the Shadowlawn residence. For these reasons, the Court concludes that the good faith exception does not apply, and any evidence seized as a result of the search of the Shadowlawn residence must be suppressed.” United States v. Harden, 2021 U.S. Dist. LEXIS 226385 (E.D.Mich. Nov. 24, 2021)