United States v. Maurice Lawrence

• Court: Court of Appeals for the Sixth Circuit
• Decided: April 3, 2026
• Docket: 25-5360
• Status: Unpublished

Opinion

NOT RECOMMENDED FOR FULL-TEXT PUBLICATION File Name: 26a0157n.06

No. 25-5360 FILED UNITED STATES COURT OF APPEALS Apr 03, 2026 FOR THE SIXTH CIRCUIT KELLY L. STEPHENS, Clerk

) UNITED STATES OF AMERICA, ) Plaintiff-Appellee, ) ) ON APPEAL FROM THE v. ) UNITED STATES DISTRICT ) COURT FOR THE MIDDLE MAURICE LAWRENCE, ) DISTRICT OF TENNESSEE Defendant-Appellant. ) ) OPINION

Before: KETHLEDGE, NALBANDIAN, and RITZ, Circuit Judges.

KETHLEDGE, Circuit Judge. A federal jury convicted Maurice Lawrence on gun and

drug charges. He now appeals the district court’s denial of his motion to suppress evidence found

in his motel room. We reject his arguments and affirm.

In October 2019, a confidential informant told Detective Ryan Kozlowski, an officer

with the Metropolitan Nashville Police Department, that Lawrence was selling drugs out of room

220 at the Kings Inn motel. Later that month, police used an informant to buy heroin from

Lawrence. Lawrence told the informant to meet him at a location near the Kings Inn, and an

undercover officer drove the informant there. When the officer and the informant arrived, the

informant entered Lawrence’s car, bought the heroin, and returned to the officer’s car. Lawrence

then drove to the Kings Inn and walked into room 220.

The next month, police set up a second controlled buy near the Kings Inn—this time for

crack cocaine. Lawrence sold the drugs to the informant, and then walked to the Kings Inn and

entered room 220. Two days later, on November 7, 2019, police arranged a third controlled buy. No. 25-5360, United States v. Lawrence

Officers watched Lawrence leave room 220 of the Kings Inn, walk to the meeting location, hand

the informant crack cocaine, and walk back to the Kings Inn.

On November 10, Detective Kozlowski applied for a search warrant to seize drugs and

drug-trafficking paraphernalia from room 220 at the Kings Inn. A state judge granted the warrant.

On November 12, police searched the motel room, where they found cocaine, fentanyl, heroin,

marijuana, drug paraphernalia, and a loaded pistol.

A federal grand jury thereafter charged Lawrence with gun and drug offenses. Lawrence

moved to suppress the evidence from the search, but the district court denied his motion. A jury

later convicted Lawrence on five counts, including possessing cocaine and fentanyl with intent to

distribute, possessing a firearm in furtherance of a drug-trafficking crime, and possessing a firearm

as a felon. See 21 U.S.C. § 841(a)(1); 18 U.S.C. §§ 924(c)(1)(A), 922(g)(1). The district court

sentenced Lawrence to 270 months in prison. This appeal followed.

Lawrence challenges the district court’s denial of his motion to suppress. We review the

district court’s legal conclusions de novo and its factual findings for clear error, viewing the

evidence in the light most favorable to the district court’s decision. See United States v. Collazo,

818 F.3d 247, 253 (6th Cir. 2016).

Lawrence argues that the police lacked probable cause to search his motel room because,

in his view, the information in the warrant affidavit went stale during the three-day period between

the November 7 controlled buy and the November 10 warrant application. Probable cause requires

“a fair probability that contraband or evidence of a crime will be found in a particular place.”

Illinois v. Gates, 462 U.S. 213, 238 (1983). Suspects often move contraband from place to place,

so information in an affidavit “can grow stale over time.” United States v. Church, 823 F.3d 351,

356 (6th Cir. 2016). And stale information cannot support probable cause for a search warrant.

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United States v. Frechette, 583 F.3d 374, 377 (6th Cir. 2009). To determine whether information

is stale, we consider the nature of the alleged crime, the suspect, the things to be seized, and the

place to be searched. United States v. Spikes, 158 F.3d 913, 923 (6th Cir. 1998). The length of

time between the events described in the affidavit and the time police apply for the warrant is

relevant, but not controlling. United States v. Abboud, 438 F.3d 554, 572–73 (6th Cir. 2006).

Here, an informant told police that Lawrence was dealing drugs from the Kings Inn

motel—information the police then corroborated with three controlled buys. Lawrence returned

to the motel after each sale, likely bringing the drug proceeds with him. During the final controlled

buy, Lawrence left his motel room (presumably carrying drugs), walked directly to the sale, and

then walked back to his room.

The state judge could have drawn at least three reasonable inferences from this information.

First, that Lawrence was engaged in an ongoing drug-dealing operation out of his motel room, and

that the November 7 transaction was not a one-off drug sale. See United States v. Greene, 250 F.3d

471, 481 (6th Cir. 2001). Second, that Lawrence was not a one-time guest at the Kings Inn motel,

but instead was “entrenched” in room 220 over a several-week period. Spikes, 158 F.3d at 923

(citation omitted). And third, that Lawrence used room 220 as a “secure operational base.” Id.

(citation omitted). Perhaps the prospect of cleaning staff entering the motel room made it less

secure than a private home, but Lawrence felt comfortable keeping drugs and drug proceeds in the

room before and after his sales. On this record, the state judge could have reasonably concluded

that the information in the affidavit remained fresh, and thus that Lawrence likely had drugs or

drug paraphernalia in his motel room three days after the last controlled buy.

Lawrence also contends that probable cause dissipated between the issuance of the warrant

on November 10 and its execution on November 12. Probable cause must exist both when the

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judge issues the warrant and when the police execute it. See United States v. Sheckles, 996 F.3d

330, 339 (6th Cir. 2021). But when a delay in execution is reasonable, and the defendant cannot

point to “changed circumstances” in the interim, the “mere passage of time” generally will not

eliminate probable cause. United States v. Archibald, 685 F.3d 553, 559–60 (6th Cir. 2012)

(abrogated on other grounds).

Here, the judge issued the warrant on a Sunday, and the police executed it on Tuesday—a

reasonable delay of only one business day. See id.; Tenn. R. Crim. P. 41(e)(3). And Lawrence

has not identified any change in circumstances during that time. Thus, the police had probable

cause to execute the warrant on November 12 for the same reasons the state judge had probable

cause to issue the warrant. Moreover, the warrant sought more than just drugs: It also

encompassed weapons and drug paraphernalia, like scales, packaging materials, and mixing

devices. These items are of “enduring utility” to a drug dealer and are therefore “unlikely . . . to

disappear” as quickly as drugs do. United States v. Burney, 778 F.3d 536, 541 (6th Cir. 2015)

(citation omitted). Probable cause therefore did not dissipate between the issuance and execution

of the warrant, and the district court properly refused to suppress the evidence that police

discovered in Lawrence’s motel room.

The district court’s judgment is affirmed.

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