AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

• On November 17, 2009, a confidential informant (CI) informed Detective Sergeant Kenneth L. Cramer (Officer Cramer) about a planned drug transaction with Orlando T. Williams, Jr. (Williams) at the Muddy Grubby Car Wash. Officer Cramer organized a controlled buy, during which he observed and listened to the transaction between the CI and Williams, leading to the arrest of Williams, the driver of the vehicle Williams was in, Mr. Guy Bell (Bell), and the CI. Subsequent interviews and admissions by Williams and Bell led Officer Cramer to Defendant Aaron Ramos, alleging Ramos was the source of the drugs. Based on this information, a search warrant was issued and executed at Ramos's residence, where drugs and a firearm were found. Ramos was charged with multiple drug-related offenses and possession of a firearm by a felon.

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Defendant-Appellant: Contended that the search warrant lacked probable cause due to the informant's unverified veracity and the officer's failure to corroborate the informant’s claims.
• Plaintiff-Appellee: Argued in response to the Defendant's motion, maintaining the validity of the search warrant and opposing the motion to suppress the evidence obtained.

Legal Issues

• Whether the affidavit for the search warrant was facially sufficient to establish probable cause for the search of Defendant's residence.

Disposition

• The Court of Appeals reversed the district court’s order denying Defendant’s motion to suppress and remanded for the district court to strike the search warrant and enter an order suppressing the evidence seized pursuant to it (Conclusion).

Reasons

• The Court, led by Judge Michael D. Bustamante with concurrence from Judges James J. Wechsler and Linda M. Vanzi, found the affidavit for the search warrant facially insufficient. The Court noted that the affidavit failed to provide sufficient additional information to establish the credibility and reliability of Williams, who was not a volunteer citizen-informant and whose statements did not qualify as against penal interest. The Court also found that Officer Cramer's affidavit lacked independent corroboration of Williams' claims against the Defendant. The Court concluded that the affidavit did not present sufficient facts for an issuing judge to determine that Williams was credible or that the information he supplied about the Defendant was accurate and worthy of belief. Therefore, the warrant should not have issued, and the evidence seized pursuant to it must be suppressed.