United States v. Brandon Hudson

CourtCourt of Appeals for the Fourth Circuit
DecidedJanuary 25, 2023
Docket21-4289
StatusUnpublished

This text of United States v. Brandon Hudson (United States v. Brandon Hudson) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fourth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Brandon Hudson, (4th Cir. 2023).

Opinion

USCA4 Appeal: 21-4289 Doc: 14 Filed: 01/25/2023 Pg: 1 of 5

UNPUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 21-4289

UNITED STATES OF AMERICA,

Plaintiff - Appellee,

v.

BRANDON QUANE HUDSON, a/k/a Blade, a/k/a Blazer,

Defendant - Appellant.

Appeal from the United States District Court for the Southern District of West Virginia, at Huntington. Robert C. Chambers, District Judge. (3:20-cr-00093-1)

Submitted: October 31, 2022 Decided: January 25, 2023

Before QUATTLEBAUM and RUSHING, Circuit Judges, and FLOYD, Senior Circuit Judge.

Affirmed by unpublished per curiam opinion.

ON BRIEF: Wesley P. Page, Federal Public Defender, Jonathan D. Byrne, Appellate Counsel, Rhett H. Johnson, Assistant Federal Public Defender, OFFICE OF THE FEDERAL PUBLIC DEFENDER, Charleston, West Virginia, for Appellant. Lisa G. Johnston, Acting United States Attorney, Courtney L. Cremeans, Assistant United States Attorney, OFFICE OF THE UNITED STATES ATTORNEY, Charleston, West Virginia, for Appellee.

Unpublished opinions are not binding precedent in this circuit. USCA4 Appeal: 21-4289 Doc: 14 Filed: 01/25/2023 Pg: 2 of 5

PER CURIAM:

Brandon Quane Hudson entered a conditional guilty plea to possession with intent

to distribute cocaine base and methamphetamine, in violation of 21 U.S.C. § 841(a)(1), and

being a felon in possession of a firearm, in violation of 18 U.S.C. §§ 922(g)(1), 924(a)(2).

The district court sentenced Hudson to 180 months’ imprisonment on each count, to be

served concurrently. On appeal, Hudson challenges the district court’s denial of his motion

to suppress evidence seized from his residence during the execution of a search warrant.

Finding no reversible error, we affirm.

“In reviewing a district court’s denial of a motion to suppress, we review legal

determinations de novo and factual findings for clear error.” United States v. Small, 944

F.3d 490, 502 (4th Cir. 2019). The Fourth Amendment protects individuals from

“unreasonable searches,” and provides that “no [w]arrants shall issue, but upon probable

cause, supported by [o]ath or affirmation, and particularly describing the place to be

searched, and the persons or things to be seized.” U.S. CONST. amend. IV. An affidavit

supporting a warrant that authorizes a search “must provide the magistrate with a

substantial basis for determining the existence of probable cause” in light of the totality of

the circumstances. Illinois v. Gates, 462 U.S. 213, 239 (1983).

Here, the district court assumed without deciding that probable cause did not exist

to support the search warrant, but concluded that the warrant was valid under the good faith

exception. This exception, as articulated in United States v. Leon, 468 U.S. 897 (1984),

holds that “evidence ‘seized in reasonable, good-faith reliance on a search warrant that is

subsequently held to be defective’ is not subject to suppression, despite the existence of a

2 USCA4 Appeal: 21-4289 Doc: 14 Filed: 01/25/2023 Pg: 3 of 5

constitutional violation.” United States v. Brunson, 968 F.3d 325, 334 (4th Cir. 2020)

(quoting Leon, 468 U.S. at 905). There are, however, four circumstances in which the good

faith exception will not apply:

(1) when the affiant based his application on knowing or reckless falsity; (2) when the judicial officer wholly abandoned his role as a neutral and detached decision maker and served merely as a “rubber stamp” for the police; (3) when the affidavit supporting the warrant was so lacking in indicia of probable cause as to render official belief in its existence entirely unreasonable; and (4) when the warrant was so facially deficient that the executing officers could not reasonably have presumed that the warrant was valid.

United States v. Wellman, 663 F.3d 224, 228-29 (4th Cir. 2011). If any of these

circumstances are present, evidence gathered pursuant to that warrant must be excluded.

See United States v. Andrews, 577 F.3d 231, 236 (4th Cir. 2009). In assessing whether the

exception applies, “our good-faith inquiry is confined to the objectively ascertainable

question whether a reasonably well trained officer would have known that the search was

illegal despite the magistrate’s authorization” in light of “all of the circumstances.” Leon,

468 U.S. at 922 n.23. Where, as here, “there are no facts in dispute, the applicability of the

Leon exception . . . is purely a legal conclusion, and we review the district court’s ruling

de novo.” United States v. DeQuasie, 373 F.3d 509, 520 (4th Cir. 2004).

Hudson argues that the district court erred in denying his motion to suppress the

evidence found during the search of his home based on the Leon good faith exception.

Specifically, Hudson contends that the nexus between his alleged drug activities and the

residence was so inadequate that the magistrate judge acted as a rubber stamp in signing

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the search warrant, and that the supporting affidavit was so bare that no police officer could

have reasonably relied on the warrant.

Our review of the record indicates that, even if the warrant was not supported by

probable cause, the affidavit contained sufficient indicia of probable cause such that the

investigator’s reliance on the warrant was objectively reasonable. Here, the affiant

investigator detailed his extensive and specialized drug investigation training, and relayed

his knowledge of a local drug trafficking organization and his identification of Hudson as

associated with the organization. Furthermore, the affiant presented facts from his

investigation demonstrating that Hudson was dealing drugs in the area around his residence

to establish a sufficient nexus between his home and the drug dealing activities. See United

States v. Williams, 548 F.3d 311, 320 (4th Cir. 2008) (concluding that courts may rely on

an officer’s “assertion of training-and experience-based knowledge” to support sufficient

nexus). The affidavit related that investigators observed Hudson entering the residence

with a key, then leaving his home on foot to conduct a suspected drug sale about a block

away. See United States v. Grossman, 400 F.3d 212, 218 (4th Cir. 2005) (noting that “it is

reasonable to suspect that a drug dealer stores drugs in a home to which he owns a key.”).

The affiant investigator described a subsequent encounter with a cooperating witness who

corroborated purchasing methamphetamine from Hudson and also revealed that Hudson

had previously sold drugs in that same area during the preceding month or two. Cf. United

States v.

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Related

Illinois v. Gates
462 U.S. 213 (Supreme Court, 1983)
United States v. Leon
468 U.S. 897 (Supreme Court, 1984)
United States v. John Lalor
996 F.2d 1578 (Fourth Circuit, 1993)
United States v. Wellman
663 F.3d 224 (Fourth Circuit, 2011)
United States v. Timothy Dequasie
373 F.3d 509 (Fourth Circuit, 2004)
United States v. Kenneth Grossman
400 F.3d 212 (Fourth Circuit, 2005)
United States v. Williams
548 F.3d 311 (Fourth Circuit, 2008)
United States v. Andrews
577 F.3d 231 (Fourth Circuit, 2009)
United States v. Dontae Small
944 F.3d 490 (Fourth Circuit, 2019)
United States v. Joey Brunson
968 F.3d 325 (Fourth Circuit, 2020)

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United States v. Brandon Hudson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-brandon-hudson-ca4-2023.