Mickey Chatham v. State

CourtCourt of Appeals of Georgia
DecidedJuly 15, 2013
DocketA13A0789
StatusPublished

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Bluebook
Mickey Chatham v. State, (Ga. Ct. App. 2013).

Opinion

FIRST DIVISION PHIPPS, C. J., ELLINGTON, P. J., and BRANCH, J.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. http://www.gaappeals.us/rules/

July 15, 2013

In the Court of Appeals of Georgia A13A0789. CHATHAM v. THE STATE.

PHIPPS, Chief Judge.

Mickey Howard Chatham was indicted for three drug offenses. He filed a

motion to suppress evidence seized from his residence pursuant to a search warrant,

contending that the warrant was issued without probable cause. Chatham filed this

interlocutory appeal from the denial of his motion to suppress. For the reasons that

follow, we reverse.

“A search warrant will only issue upon facts sufficient to show probable cause

that a crime is being committed or has been committed.”1

1 State v. Palmer, 285 Ga. 75, 77 (673 SE2d 237) (2009) (citation omitted); OCGA § 17-5-21 (a). In determining probable cause for the issuance of a search warrant, the issuing magistrate must make a practical, common-sense decision whether, given all the circumstances set forth in the affidavit before him, including the veracity and basis of knowledge of persons supplying hearsay information, there is a fair probability that contraband or evidence of a crime will be found in a particular place.2

Where, as here,

a motion to suppress is made on one of the three statutory grounds enumerated in OCGA § 17-5-30 (a) (2), challenging the validity of a search and seizure with a warrant, the burden of showing that the search and seizure were lawful shall be on the state. This burden upon the state is satisfied by production of the warrant and its supporting affidavit, and by showing either by those documents or by other evidence that the warrant is not subject to the statutory challenge alleged.3

Our appellate courts will review the search warrant to determine the existence of probable cause using the totality of the circumstances analysis set forth in Illinois v. Gates.[4] The duty of the appellate courts is to determine if the magistrate had a substantial basis for concluding

2 Browner v. State, 265 Ga. App. 788, 789 (1) (595 SE2d 610) (2004) (citations omitted). 3 Davis v. State, 266 Ga. 212, 213 (465 SE2d 438) (1996) (citation and punctuation omitted). 4 462 U. S. 213 (103 SCt 2317, 76 LE2d 527) (1983).

2 that probable cause existed to issue the search warrant. . . . In reviewing the trial court’s grant or denial of a motion to suppress, we apply the well-established principles that the trial court’s findings as to disputed facts will be upheld unless clearly erroneous and the trial court’s application of the law to undisputed facts is subject to de novo review, keeping in mind that a magistrate’s decision to issue a search warrant based on a finding of probable cause is entitled to substantial deference by a reviewing court.5

At the hearing on the motion to suppress, the state produced the affidavit and

application that the attesting law enforcement officer submitted in support of the

request for a search warrant. In the affidavit, dated December 3, 2011, the officer

pertinently averred that he had met with a confidential informant (“CI”) who claimed

to have personal knowledge that Chatham was selling crystal methamphetamine from

a residence at a particular address on Westfall Road, and that the CI could purchase

crystal methamphetamine from Chatham inside that residence. After searching the

CI’s person and vehicle and finding no contraband or currency, the officer gave the

5 Palmer, supra at 78 (citations and punctuation omitted).

3 CI funds with which to purchase drugs “and directed [CI] to the [specified] residence

to attempt a narcotics purchase.”6 The affidavit provided further:

[The officer] then acted in an undercover capacity and followed CI to within a short distance of the [specified] residence, observing CI’s vehicle on Westfall Road. A short time later, [the officer] met with CI at a predetermined meeting location and CI immediately handed [the officer] a quantity of suspected crystal methamphetamine. CI stated that it purchased the suspected crystal methamphetamine from Mickey Howard Chatham from inside the above-mentioned residence in exchange for the undercover drug purchasing funds. [The officer] then searched the CI’s person and vehicle and no contraband or currency was located.

The officer averred further that the “CI has a criminal history” and is a convicted

felon. He also averred that the CI had provided directions to and a description of the

residence, and that fellow law enforcement officers knew that Chatham lived at that

residence. The officer averred that the “CI has participated in at least one (1) narcotics

investigation (this investigation)[7] where crystal methamphetamine was seized[,]

[and] at no time has the CI shown or expressed any ill will or malice towards . . .

6 In the affidavit, the affiant sometimes referred to the confidential informant as “it” or “CI.” 7 (Emphasis supplied.)

4 Chatham.” The record does not show, and the state does not claim, that any additional

information was presented to the magistrate. The magistrate concluded that probable

cause existed and issued the search warrant (which warrant was admitted into

evidence at the suppression hearing). Officers executed the search warrant, seizing

pursuant thereto suspected crystal methamphetamine. In announcing its ruling at the

hearing on the suppression motion, the trial court remarked that the officer had

“followed the protocol” by searching the CI before and after the CI obtained the

drugs, but noted that the police had not seen or recorded the purported transaction.

Chatham contends that the trial court erred by denying the motion to suppress

when the search warrant was issued based upon the statements of a CI whose

reliability, credibility and source of information were unknown, and law enforcement

officers had failed to corroborate the CI’s claim that Chatham was selling drugs from

the residence. We agree.

Where the state seeks to show probable cause through information gained from an unidentified informant, the informant’s veracity and basis of knowledge are major considerations in the probable cause analysis. An informant’s information shows nothing more than rumor if the affidavit does not contain sufficient facts for the magistrate to independently determine the reliability of the informant or the basis of the informant’s knowledge. However, there is no absolute requirement

5 that a search warrant affiant state circumstances which demonstrate the reliability of the informant and his information. Those factors are highly relevant considerations, but the applicable test is based on the totality of the circumstances.8

Further, “[e]ven if an unidentified informant is not shown to be trustworthy, [his or]

her tip may be proved reliable if portions of it are sufficiently corroborated by the

police.”9 “Once a motion to suppress has been filed, the burden of proving the

lawfulness of the [search] warrant is on the state and that burden never shifts.”10

In this case, the affidavit did not contain sufficient information from which the

magistrate could determine that the CI was inherently credible or reliable, or the basis

of his or her knowledge.

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Related

Illinois v. Gates
462 U.S. 213 (Supreme Court, 1983)
Ibekilo v. State
626 S.E.2d 592 (Court of Appeals of Georgia, 2006)
Davis v. State
465 S.E.2d 438 (Supreme Court of Georgia, 1996)
Hamilton v. State
436 S.E.2d 500 (Court of Appeals of Georgia, 1993)
Evans v. State
588 S.E.2d 764 (Court of Appeals of Georgia, 2003)
Browner v. State
595 S.E.2d 610 (Court of Appeals of Georgia, 2004)
Turner v. State
544 S.E.2d 765 (Court of Appeals of Georgia, 2001)
Brown v. State
535 S.E.2d 785 (Court of Appeals of Georgia, 2000)
State v. Alvin
674 S.E.2d 348 (Court of Appeals of Georgia, 2009)
State v. Palmer
673 S.E.2d 237 (Supreme Court of Georgia, 2009)
Campbell v. State
589 S.E.2d 313 (Court of Appeals of Georgia, 2003)
Sullivan v. State
667 S.E.2d 32 (Supreme Court of Georgia, 2008)
Fiallo v. State
523 S.E.2d 355 (Court of Appeals of Georgia, 1999)
Lyons v. State
572 S.E.2d 632 (Court of Appeals of Georgia, 2002)
Davis v. State
568 S.E.2d 161 (Court of Appeals of Georgia, 2002)
Tackett v. State
440 S.E.2d 74 (Court of Appeals of Georgia, 1994)
St. Fleur v. State
649 S.E.2d 817 (Court of Appeals of Georgia, 2007)

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Bluebook (online)
Mickey Chatham v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mickey-chatham-v-state-gactapp-2013.