Tyrone Dexter Christian v. United States
AdministrativeLaw FourthAmendment CriminalProcedure Privacy
Whether the lower court erred in finding probable cause to search petitioner's home when the court viewed the search warrant affidavit as a whole and failed to individually analyze the weight of each factor
QUESTIONS PRESENTED In Illinois v. Gates, 462 U.S. 213 (1983), this Court sanctioned a “totality of the circumstances” approach for evaluating the factors relevant for determining probable cause. Several federal courts of appeals have concluded that this Court’s totality of the circumstances test requires analysis of each individual probable cause factor followed by an evaluation of the factors as a whole. In United States v. Leon, 468 U.S. 897 (1984), this Court held that while the exclusionary rule should not apply to bar evidence when an officer relies in good-faith on a search warrant, it should apply to bar evidence when the warrant is objectively devoid of facts supporting probable cause. The questions presented for review are: L. Whether the lower court erred in finding probable cause to search petitioner’s home when the court viewed the search warrant affidavit as a whole and failed to individually analyze the weight of each factor. I. Whether the lower court erred when the court found that the goodfaith exception to the exclusionary rule should apply to permit the introduction of evidence seized from petitioner’s home, even though the search warrant affidavit was overly vague and conclusory and failed to provide a minimal connection between the alleged criminal activity and petitioner’s home. ii