United States v. Kirtdoll, No. 23-1585 (6th Cir. 2024)
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The case involves Tommy Kirtdoll, who was under investigation by a multijurisdictional task force in southwest Michigan for leading a drug-trafficking organization. After several undercover drug deals, the task force obtained a search warrant for Kirtdoll's house, which was described in detail in the warrant application. Upon executing the warrant, officers found drugs and distribution equipment, leading to Kirtdoll's indictment on multiple drug offenses.
Kirtdoll challenged the validity of the search warrant, citing three errors: the address listed was not his, the tax identification number was incorrect, and the property owner's name was not his. He argued that these mistakes rendered the warrant unconstitutional due to lack of particularity, as required by the Fourth Amendment. The district court denied Kirtdoll's motion, ruling that the warrant's other accurate descriptors were particular enough to satisfy the Fourth Amendment. Kirtdoll pleaded guilty but reserved the right to appeal the district court's decision.
The United States Court of Appeals for the Sixth Circuit reviewed the warrant's particularity de novo. The court held that the Fourth Amendment does not require perfection in search warrants, but rather enough detail for the executing officer to identify the intended place with reasonable effort. The court found that despite the errors, the warrant contained three descriptors that indisputably applied only to Kirtdoll's house and clearly identified it as the premises to be searched. These included the house's geographic location, a detailed description of the house, and a unique identifier - a red star affixed to its west side. The court concluded that the warrant for Kirtdoll's house was specific enough to meet the Fourth Amendment's particularity requirement, and thus, the district court properly denied Kirtdoll's motion to suppress. The court affirmed the district court's decision.
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