United States v. Guzman-Batista, No. 14-1059 (1st Cir. 2015)
Annotate this CaseDefendant was indicted for violating 18 U.S.C. 922(n), which makes it unlawful for a person who is under indictment for a certain category of crime to receive any firearm or ammunition which has been transported in interstate or foreign commerce. Defendant filed a motion to suppress, alleging that the evidence seized from his home was discovered pursuant to a state search warrant filled with false statements, and that without those statements, probable cause for the warrant was lacking. After a Franks hearing, the magistrate judge recommended that the district court grant the motion to suppress, concluding that the sworn statement in support of the search warrant had false and misleading information, without which probable cause for the search warrant was insufficient. After a de novo Franks hearing, the district court rejected the magistrate’s report and recommendation and denied Defendant’s motion to suppress. The First Circuit affirmed, holding that because Defendant’s argument boiled down to a credibility determination by the district court - something that the First Circuit will not second-guess - there was easily probable cause to issue the search warrant, and therefore, Defendant’s motion to suppress was properly denied.
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