The case arose from a March 2024 drug investigation in Starkville, Mississippi, where police executed a search warrant at Lexus Sanchez Weaver's home based on three controlled drug buys using a confidential informant. Officers found methamphetamine, cocaine, firearms, money and cellphones during the search, leading to Weaver's arrest on five drug trafficking and firearm possession counts.
Circuit Judge Edith H. Jones wrote that the district court incorrectly found the warrant affidavit was "bare bones," noting it contained "sufficient detail: time frames of the drug buys; the address of Weaver's residence; the type of drug; the controlled buy process" and other specifics. The panel found the affidavit "went far beyond conclusory statements relying on a CI or mere indications of the offense committed," distinguishing it from truly deficient warrants in prior cases.
The district court had granted Weaver's motion to suppress both the search evidence and his interview statements, finding the warrant lacked probable cause and that Weaver didn't properly waive his Miranda rights when he signed a form he thought only acknowledged being read his rights. The government appealed the suppression ruling.
While the Fifth Circuit reversed the evidence suppression under the good-faith exception, it remanded for further proceedings on Weaver's statements, noting the district court failed to analyze whether he implicitly waived his Miranda rights despite problems with his express written waiver. The panel retained jurisdiction pending the district court's decision on remand.