United States v. Taylor

774 F. Supp. 41, 1991 U.S. Dist. LEXIS 14504, 1991 WL 205451
CourtDistrict Court, D. Maine
DecidedSeptember 27, 1991
DocketCrim. A. Nos. 91-00056-B-01, 91-00056-B-02
StatusPublished

This text of 774 F. Supp. 41 (United States v. Taylor) is published on Counsel Stack Legal Research, covering District Court, D. Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Taylor, 774 F. Supp. 41, 1991 U.S. Dist. LEXIS 14504, 1991 WL 205451 (D. Me. 1991).

Opinion

ORDER AND MEMORANDUM OF OPINION

BRODY, District Judge.

Defendants Michael and Jean Taylor were indicted on July 23, 1991 under 21 U.S.C. § 841 and 18 U.S.C. § 2 for knowingly and intentionally manufacturing a quantity of marijuana and aiding and abetting the commission of that offense. The Taylors have moved to suppress the marijuana plants and drug paraphernalia seized when law enforcement officers executed a search warrant issued by a Maine state court judge. A hearing on the motion was held on September 20, 1991. For the reasons stated below, defendants’ motion is DENIED.

On July 17, 1991, the Bureau of Intergovernmental Drug Enforcement (“BIDE”) [42]*42sought and obtained a warrant authorizing the search of Michael and Jean Taylor’s mobile home. The affiant, Special Agent Robert Hutchings, stated that probable cause to believe that the Taylors were growing marijuana was established by his conversation with a confidential informant, Cl # 911, who had “provided reliable information in the past.” The informant reported that: Mike and Jean Taylor were both raising marijuana plants; that within the past two weeks he had personally observed numerous plants growing around the structure in which Mike lived, numerous marijuana plants growing in Jean’s garden and a four foot plant growing by Jean’s trailer door; that six weeks earlier, Jean had hundreds of seedlings set out in her backyard and that he had heard Jean Taylor complain about the amount of work required to care for so many plants; and that earlier in the winter he had observed numerous seedlings being started in Mike’s trailer. The only independent “investigation” or “corroboration” which the affidavit mentions is Hutchings’ review of a five year old case disposition report indicating that Jean Taylor had pleaded guilty to two counts of trafficking in marijuana in state court on October 8, 1986 and a five year old affidavit which presumably served as the basis for the search warrant leading to Jean Taylor’s 1986 conviction.

Michael and Jean Taylor argue that the affidavit fails to establish probable cause and that all of the marijuana plants and drug paraphernalia seized must be suppressed. Defendants complain, in particular, that the reliability of the informant is not adequately established1 and that the information provided by the informant is stale.

We first address whether the affidavit provides enough information about the reliability of the informant to support a finding of probable cause. We conclude that in the wake of the Supreme Court’s decision in Illinois v. Gates, 462 U.S. 213, 103 S.Ct. 2317, 76 L.Ed.2d 527 (1983), the affidavit is sufficient despite the conclusory and unsubstantiated description of the informant’s reliability and the absence of independent corroboration.

Historically, confidential informants have been treated as the least credible source of information about the commission of crimes not only because informants enjoy anonymity, but also because they are often “criminals, drug addicts, or even pathological liars.” Michael Rebell, The Undisclosed Informant and the Fourth Amendment: A Search for Meaningful Standards, 81 Yale L.J. 703, 712-13 (1972) (also noting that many informants provide information only to avoid being prosecuted themselves). Although indispensable, confidential informants are generally regarded as less reliable than ordinary citizens, victims, or law enforcement officers. Under Aguilar v. Texas, 378 U.S. 108, 84 S.Ct. 1509, 12 L.Ed.2d 723 (1964) and Spinelli v. United States, 393 U.S. 410, 89 S.Ct. 584, 21 L.Ed.2d 637 (1969), courts reviewing probable cause determinations based on information from confidential informants applied a two prong test, analyzing the informant’s basis of knowledge and veracity. An informant’s reliability and credibility (i.e., veracity) were traditionally established by providing a judicial officer reviewing a warrant application with sufficient information about the informant’s “track record” to permit an independent evaluation of the informant’s reliability, through self-verifying details in the informant’s story, or through independent police investigation which corroborated material portions [43]*43of the informant’s story. The inclusion of admissions against interest in an informant’s story also tended to establish the informant’s reliability. In Illinois v. Gates, 462 U.S. 213, 103 S.Ct. 2317, 76 L.Ed.2d 527 (1983), the Supreme Court abandoned the Aguilar-Spinelli two prong test, establishing a unitary “totality-of-the-circumstances analysis.”

The First Circuit recently applied Gates “totality-of-the-circumstances” test to two affidavits which stated that “[t]his informant has proven reliable in the past by supplying information resulting in the arrest of several people for drug related offenses.” United States v. Caggiano, 899 F.2d 99, 102 n. 2 (1st Cir.1990).2 Conceding that “the reliability information in the both affidavits is more conclusory than specific” the First Circuit stated that “the reliability of the informants was enhanced by the specificity and details given to [the affiant] of what they saw and heard while they were in defendant’s apartment.” Id. at 102. The affidavit contained no other information bearing on the informants’ reliability. As in the instant ease, the informants in Caggiano told police they had observed drugs at the defendant’s residence and heard the defendant discuss the drug transactions. The “specificity and detail ]” of the information provided by the confidential informant in the instant case is at least as great as in Caggiano. We are therefore constrained to find that Hutchings’ conclusory statement that the confidential informant is reliable together with the specific and detailed information provided by that informant provided “ ‘a substantial basis for concluding that probable cause existed.’ ” Caggiano, 899 F.2d at 103 (quoting Gates, 462 U.S. at 238-39, 103 S.Ct. at 2332).3

We next examine the defendants’ claim that the search warrant failed to establish probable cause because the information in it was “stale.” Without citation to authority, defendants argue that the warrant was devoid of probable cause because it was based on observations of drugs that were two weeks, six weeks or six months old. “Whether or not the averments in the affidavit are sufficiently timely to establish probable cause depends on the particular circumstances of the case. Where the information points to illegal activity of a continuous nature, the passage of several months between the observations in the affidavit and issuance of a warrant will not render the information stale.” United States v. Hershenow, 680 F.2d 847, 853 (1st Cir.1982) (citing United States v. DiMuro,

Related

Aguilar v. Texas
378 U.S. 108 (Supreme Court, 1964)
Spinelli v. United States
393 U.S. 410 (Supreme Court, 1969)
Brown v. Illinois
422 U.S. 590 (Supreme Court, 1975)
Illinois v. Gates
462 U.S. 213 (Supreme Court, 1983)
United States v. Leon
468 U.S. 897 (Supreme Court, 1984)
United States v. James A. Dauphinee
538 F.2d 1 (First Circuit, 1976)
United States v. Allen J. Caggiano
899 F.2d 99 (First Circuit, 1990)
United States v. John Jeffrey Soule
908 F.2d 1032 (First Circuit, 1990)
United States v. Moscatiello
771 F.2d 589 (First Circuit, 1985)
United States v. Mitro
880 F.2d 1480 (First Circuit, 1989)
Carter v. United States
476 U.S. 1138 (Supreme Court, 1986)
Isaac v. United States
476 U.S. 1138 (Supreme Court, 1986)
United States v. DiMuro
540 F.2d 503 (Tenth Circuit, 1976)

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Bluebook (online)
774 F. Supp. 41, 1991 U.S. Dist. LEXIS 14504, 1991 WL 205451, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-taylor-med-1991.