United States v. Patrick Bradley

CourtCourt of Appeals for the Sixth Circuit
DecidedOctober 20, 2025
Docket24-3906
StatusUnpublished

This text of United States v. Patrick Bradley (United States v. Patrick Bradley) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth 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. Patrick Bradley, (6th Cir. 2025).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 25a0480n.06

No. 24-3906

UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT FILED Oct 20, 2025 ) KELLY L. STEPHENS, Clerk UNITED STATES OF AMERICA, ) Plaintiff-Appellee, ) ON APPEAL FROM THE UNITED ) v. STATES DISTRICT COURT FOR THE ) NORTHERN DISTRICT OF OHIO ) PATRICK BRADLEY, ) Defendant-Appellant. OPINION ) )

Before: KETHLEDGE, LARSEN, and BLOOMEKATZ, Circuit Judges.

KETHLEDGE, Circuit Judge. Patrick Bradley appeals the district court’s denial of his

motion to suppress drug-trafficking evidence that the police found at his residence. We reject his

arguments and affirm.

I.

In January 2020, Ohio police intercepted a package containing one pound of

methamphetamine on its way to a house on Nicholas Place in Canton, Ohio. The package was

addressed to “Cindy Williams.” Law enforcement conducted a controlled delivery of the drugs,

leaving the package on the doorstep after no one answered the door. Patrick Bradley soon walked

out of the house, picked up the package, and put it in a trash can. No. 24-3906, United States v. Bradley

Later that year, three informants told police that Bradley was selling methamphetamine

and cocaine. An FBI task force then placed Bradley under surveillance.

In November 2020, Bradley sold two ounces of cocaine to a police informant. The

informant met with Bradley four times to make installment payments for the drugs. On one

occasion, Bradley left the house on Nicholas Place to meet the informant for payment; on another,

Bradley met the informant to receive payment and then returned to that same house. When he met

the informant, Bradley drove a car registered to the Nicholas Place address.

Bradley again sold drugs to the police informant two months later. He and the informant

spent a day haggling over the sale via call and text. Bradley made one of these calls from the

Nicholas Place house. Bradley offered to sell the informant one pound of methamphetamine; the

informant told Bradley that he wanted only an ounce. That evening, Bradley left Nicholas Place,

made several stops around Canton, and then met the informant to sell him the methamphetamine.

He again returned to the Nicholas Place house.

Ohio police applied for a warrant to search the house for drugs, drug proceeds, and other

evidence of drug trafficking. A state judge granted the warrant that night. Police executed the

search just after midnight, seizing nearly 300 grams of methamphetamine, 144 grams of cocaine,

52 grams of MDMA, and 33 grams of an MDMA and cocaine mixture from the home.

A grand jury thereafter indicted Bradley on three counts of possession with intent to

distribute a controlled substance in violation of 21 U.S.C. §§ 841(a)(1), (b)(1)(A)(viii), and

(b)(1)(C). Bradley moved to suppress the evidence found at the Nicholas Place house, arguing

that the warrant was not supported by probable cause. The district court denied that motion and a

motion for reconsideration.

-2- No. 24-3906, United States v. Bradley

Shortly before trial, the government produced cellphone data that police had seized from

one of Bradley’s phones. At trial, a jury convicted Bradley on all counts. In January 2024, Bradley

moved to reopen his suppression hearing. The court denied the motion. Bradley filed another

such motion in September 2024, three days before his sentencing hearing. The court denied that

motion and struck it from the record. The court then sentenced Bradley to 210 months in prison.

This appeal followed.

II.

A.

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

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

evidence in the light most favorable to the court’s decision. See United States v. Russell, 26 F.4th

371, 374 (6th Cir. 2022). Our review of the state judge’s decision to grant the warrant is likewise

deferential. See United States v. Brown, 732 F.3d 569, 573 (6th Cir. 2013).

Bradley argues that the police lacked probable cause to search the Nicholas Place house.

Probable cause for a search warrant exists when there is a “fair probability that the specific place

to be searched contained the specific things to be seized.” United States v. Sheckles, 996 F.3d 330,

340 (6th Cir. 2021). A drug dealer’s “status alone” is not enough to establish probable cause to

search his residence. United States v. Reed, 993 F.3d 441, 448 (6th Cir. 2021). But the government

has grounds to search a known drug dealer’s residence when the dealer is “engaged in continual

and ongoing operations typically involving large amounts of drugs.” United States v. Sanders,

106 F.4th 455, 466 (6th Cir. 2024) (en banc) (citation omitted). In these circumstances, a judge

can “infer that drug traffickers use their homes to store drugs and otherwise further their drug

trafficking.” United States v. Williams, 544 F.3d 683, 687 (6th Cir. 2008). A warrant affidavit

-3- No. 24-3906, United States v. Bradley

fortifies this inference when it provides additional evidence connecting the dealer’s operations to

the residence. See Sheckles, 996 F.3d at 341-42.

Bradley was a known drug dealer engaged in continuous and ongoing trafficking

operations. Three informants told police that Bradley sold cocaine and methamphetamine.

Police corroborated these tips by using an informant to purchase drugs from Bradley twice.

Bradley regularly updated this informant on his efforts to secure additional drug shipments. And

Bradley distributed these drugs in large quantities: he offered to sell one informant one pound of

methamphetamine and reportedly sold a “half a brick” of cocaine to another.

Moreover, Bradley listed the house’s address on his car registration, which gave police

“good reason to think that [Bradley] had some substantial connection to that address.” United

States v. Jones, 817 F.3d 489, 491 (6th Cir. 2016). And when police conducted a controlled

delivery of a methamphetamine package to the Nicholas Place house, Bradley walked out, picked

up the package, and threw it in the trash can—hardly the behavior of a house guest. In addition,

in the weeks leading up to the search, the police saw Bradley come or go from the house, including

late at night.

Bradley asserts he no longer lived at Nicholas Place on the night of the search. Specifically,

he says that his ex-girlfriend lived in the house, that he had broken up with her and moved out, and

that he stayed there overnight only to visit his daughter. But Bradley cites nothing in the record

that would have given the police any reason to make that distinction between resident and frequent

overnight guest. And the Fourth Amendment requires officers to act only “reasonably,” not

“flawlessly.” United States v. Rohrig, 98 F.3d 1506, 1524 (6th Cir. 1996).

-4- No. 24-3906, United States v. Bradley

Meanwhile, the warrant affidavit recited evidence linking Bradley’s drug operation to the

Nicholas Place house.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

United States v. Donald P. Rohrig
98 F.3d 1506 (Sixth Circuit, 1996)
United States v. Sidney Brown
732 F.3d 569 (Sixth Circuit, 2013)
United States v. Williams
544 F.3d 683 (Sixth Circuit, 2008)
United States v. Steven Pittman
816 F.3d 419 (Sixth Circuit, 2016)
United States v. Dionte Jones
817 F.3d 489 (Sixth Circuit, 2016)

Cite This Page — Counsel Stack

Bluebook (online)
United States v. Patrick Bradley, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-patrick-bradley-ca6-2025.