Clarifying the Nexus: Parole-Registered Residence and a Single Curbside Transaction Can Establish Probable Cause to Search a Known Drug Dealer’s Home

Introduction

In United States v. Devin Long, No. 24-3377 (6th Cir. Oct. 17, 2025) (recommended for publication), the Sixth Circuit affirmed the denial of a motion to suppress evidence seized from the defendant’s home under a search warrant. The panel—Judge Readler writing for the court, joined by Judge Murphy, with Judge Bloomekatz concurring in the judgment—held that the warrant affidavit established a sufficient “nexus” between Long’s residence and ongoing drug trafficking to support probable cause.

The decision reinforces two doctrinal strands in the Sixth Circuit’s Fourth Amendment jurisprudence: (1) the “known drug dealer” line of cases, which recognizes that when an affidavit shows a suspect is engaged in ongoing trafficking and the location to be searched is the suspect’s residence, the common-sense inference that evidence will be found at home typically supplies the required nexus; and (2) the “curbside transaction” cases, which hold that an observed drug deal outside a residence, followed by the suspect’s immediate return to the residence, independently supports probable cause to search the home. The court also clarifies that a residence listed with a government supervision authority (here, the Ohio Adult Parole Authority) is sufficient proof of residence for nexus purposes, that a suspect need not be a “known” dealer at the outset of an investigation to qualify under the doctrine, and that affidavits are judged by what they contain, not by facts they might have contained.

Summary of the Opinion

DEA task force officers surveilled a drug trafficking ring involving methamphetamine, fentanyl, and cocaine, initially targeting Isiah Crenshaw. Controlled buys directed the investigation toward Devin Long. Officers observed:

Long’s presence with Crenshaw and another associate (Hall) immediately before and after a controlled buy, including a transfer of what appeared to be proceeds;
Long’s separate suspected drug transaction at a Family Dollar after leaving a suspected stash house;
Long delivering an orange bag later found to contain methamphetamine used in a controlled buy with Hall;
A hand-to-hand exchange outside Long’s registered residence (on 35th Street), followed by the intermediary’s delivery to another car and Long’s return into his home;
Repeated travel between Long’s home and a suspected stash house (on 46th Street); and
Trash pulls and surveillance indicating the 46th Street house functioned as a stash location, while Long stored proceeds at home.

On this record, a magistrate judge issued a warrant to search Long’s 35th Street residence. The search uncovered multiple controlled substances, cutting agents, six firearms, ammunition, and magazines. After the district court denied his suppression motion, Long pleaded guilty to drug and firearms offenses, preserving the suppression issue for appeal.

The Sixth Circuit affirmed. Applying deferential “substantial basis” review to the issuing magistrate’s probable cause determination, the court held that the affidavit satisfied the known-drug-dealer nexus standard because it (a) identified the residence as Long’s home (based on his parole registration) and (b) showed ongoing trafficking. The court added that the single observed transaction outside the home, followed by Long’s immediate re-entry, independently supported probable cause under circuit precedent. Judge Bloomekatz concurred in the judgment but cautioned against parsing the facts into separate, independently sufficient subsets, emphasizing instead that probable cause must be assessed under the totality of the circumstances.

Analysis

Precedents Cited and Their Role

Illinois v. Gates, 462 U.S. 213 (1983) and Maryland v. Pringle, 540 U.S. 366 (2003): The bedrock “totality of the circumstances” framework and “fair probability” standard. The panel repeatedly anchors its analysis in Gates/Pringle, emphasizing that probable cause is not a precise formula but a common-sense, probability-based judgment.
United States v. Sanders, 106 F.4th 455 (6th Cir. 2024) (en banc): The Sixth Circuit’s recent en banc articulation of the “known drug dealer” nexus doctrine. When an affidavit shows the suspect’s residence and ongoing trafficking, a magistrate may infer that evidence will be found at home. Sanders also underscores deference to issuing judges, framing appellate review around whether the magistrate had a “substantial basis.”
United States v. Simmons, 129 F.4th 382 (6th Cir. 2025): Applies Sanders to uphold a residence search despite no direct evidence of dealing at the home. Notably, Simmons recognizes that a government-supervision-listed address (there, federal probation; here, state parole) suffices to establish residence. Long builds on Simmons by taking the suspect “at his word” when he provides an address to a supervisory authority.
United States v. Higgins, 141 F.4th 811 (6th Cir. 2025): Cited for the proposition that residence plus continual dealing alone can supply probable cause to search the home.
United States v. Sheckles, 996 F.3d 330 (6th Cir. 2021) and United States v. Carpenter, 360 F.3d 591 (6th Cir. 2004) (en banc): Define and apply the “nexus” requirement—probable cause must link the place to be searched and the evidence sought. Sheckles is invoked for the principle that direct evidence of dealing at the home is not required in “known drug dealer” cases.
United States v. Reed, 993 F.3d 441 (6th Cir. 2021) and United States v. Sumlin, 956 F.3d 879 (6th Cir. 2020): Affirm that an officer’s training and experience—particularly that traffickers commonly keep records, contraband, and proceeds at home—may be considered as an “additional reason” supporting probable cause when paired with evidence of ongoing dealing.
United States v. Ellison, 632 F.3d 347 (6th Cir. 2011); United States v. White, 990 F.3d 488 (6th Cir. 2021); United States v. Berry, 565 F.3d 332 (6th Cir. 2009): The “curbside transaction” line. An observed drug deal outside a residence, followed by return into the residence, can itself establish probable cause to search the home. The panel treats Long’s outside-the-home exchange as an independent nexus-supplying basis.
United States v. Florence, 150 F.4th 773 (6th Cir. 2025): Cited for the proposition that even a single drug transaction can be sufficient for probable cause in appropriate circumstances.
United States v. Kenny, 505 F.3d 458 (6th Cir. 2007): Supports the clarification that “known drug dealer” status need not pre-exist the investigation; it can be established during it. This rebuts the argument that only pre-identified dealers fall within the doctrine.
United States v. Stearn, 597 F.3d 540 (3d Cir. 2010): Cited by Sanders and echoed here for the idea that the existence of another residence does not diminish probable cause for the listed residence; the nexus inquiry is probabilistic, not exclusive.
United States v. Allen, 211 F.3d 970 (6th Cir. 2000) (en banc): Reinforces the four-corners principle: affidavits are evaluated based on what they contain, not on hypothetically “missing” facts.
Florida v. Harris, 568 U.S. 237 (2013) and Kaley v. United States, 571 U.S. 320 (2014): Emphasize that probable cause does not require refuting every innocent explanation and that the bar is “not high.”
United States v. Christian, 925 F.3d 305 (6th Cir. 2019) (en banc); United States v. Taylor, 121 F.4th 590 (6th Cir. 2024): Standards of review: deferential substantial-basis review of the issuing judge’s probable cause determination; clear-error for facts, de novo for legal conclusions.
Weeks v. United States, 232 U.S. 383 (1914): The suppression remedy is available for Fourth Amendment violations; cited as background.

Legal Reasoning

The court proceeds along two reinforcing paths, each sufficient to sustain the magistrate’s finding, and both easily adequate under the totality of circumstances:

Known drug dealer nexus. The affidavit (a) identified the 35th Street address as Long’s residence—based on his own registration with the Ohio Adult Parole Authority—and (b) established ongoing, continual trafficking. The panel stresses that when a suspect provides a residence to a governmental supervision authority, courts “take him at his word” for Fourth Amendment nexus purposes. Combining residence with repeated observations of trafficking behavior (controlled buys tied to Long, delivery of an orange bag later found to contain meth for a controlled buy, a Family Dollar exchange, frequent travel between a stash house and home), plus the affiant’s experience that dealers keep contraband/records at home, yielded more than a fair probability that evidence would be found at Long’s residence.
- The court rejects Long’s contention that there must be direct proof of dealing from within the home: the doctrine does not require it, though here there was an additional direct tie—the curbside exchange at Long’s home.
- The court clarifies that a defendant’s “known” status need not predate the investigation; what matters is whether the affidavit ultimately shows ongoing trafficking.
- The existence of other possible residences does not defeat nexus to the listed home.
Curbside transaction as an independent basis. The officers observed an exchange outside Long’s home consistent with a hand-to-hand drug deal, followed by the intermediary returning to Long’s car and Long’s immediate re-entry into his residence. Under Ellison, White, and Berry, a single observed drug transaction at or just outside a residence, with prompt return, can itself establish the nexus to search the home. The panel underscores that probable cause does not demand excluding every innocent possibility (e.g., returning car keys); it requires only a fair probability grounded in training, experience, and common sense.

The majority handles several defense arguments along the way:

No need for “missing” facts. The affidavit need not recite drug quantities, detailed international links, more extensive criminal history, or an insider’s description of the home’s interior. Allen instructs courts to evaluate the four corners, and none of those facts is necessary under Sixth Circuit precedent.
Residence is established by parole registration. As in Simmons, the defendant’s own representation to supervising authorities is sufficient proof of residence for the nexus analysis, notwithstanding surveillance suggesting he also frequented other locations.
Analogical reach beyond narcotics. Responding to hypotheticals, the majority suggests the same common-sense nexus logic would apply to non-drug schemes (e.g., ransomware), though that discussion is dicta. The core teaching is that the nexus inquiry is activity-specific but not crime-category dependent.

The Concurrence

Judge Bloomekatz concurs in the judgment but cautions against segmenting the analysis into independently sufficient strands. She emphasizes Gates’s totality-of-the-circumstances approach and would affirm simply because, taken together, all the facts establish a fair probability that evidence would be found in Long’s home. The concurrence signals a methodological preference: future panels should avoid advisory statements about what “would have been enough” on fewer facts when the totality already suffices.

Impact and Practical Implications

The decision meaningfully consolidates and clarifies Sixth Circuit law at several points:

Residence proof through supervision records. A defendant’s address registered with a probation or parole authority is sufficient to establish the “residence” component of the known-drug-dealer nexus. This eases the government’s burden when supervision records exist and cautions defendants that listing an address has evidentiary consequences.
“Known” refers to status at the warrant stage, not at investigation inception. The court squarely rejects the notion that the doctrine applies only if the suspect was already “known” to be a dealer before the investigation. Ongoing conduct revealed during surveillance suffices.
One curbside deal can be enough. The reaffirmation of Ellison/White/Berry will continue to support residence searches where officers observe a single transaction outside a home followed by the suspect’s return inside—especially when accompanied by other trafficking indicators.
Officer training and experience remains a legitimate, additive factor. Affidavits should document the affiant’s knowledge that traffickers keep evidence at home. While not standalone, this factor strengthens the nexus when coupled with ongoing dealing.
Affidavits judged by what they contain. Challenges premised on “missing” details are unlikely to prevail absent a Franks-type showing; defendants should focus on undermining the reasonableness of the inferences actually drawn from the stated facts.
Totality remains the touchstone. Although the majority notes independently sufficient strands, the concurrence’s admonition may influence future opinions to emphasize totality without parsing hypotheticals about minimal sufficiency.

For practitioners:

Investigators and prosecutors. Tie the suspect to the residence through official records (probation/parole/DMV/utilities) when possible; document the pattern of trafficking with dates, locations, controlled buys, and travel between stash house(s) and home; include succinct training-and-experience paragraphs on how traffickers store evidence.
Defense counsel. Where possible, contest whether “ongoing” trafficking is sufficiently shown (staleness, isolated events), scrutinize the characterization of ambiguous exchanges, and probe whether the affidavit’s inferences are supported by concrete facts rather than conclusory assertions. Consider whether a totality framing (per the concurrence) cuts against reliance on any single weak strand.
Magistrate judges. The decision affirms that substantial-basis review protects predictive, common-sense judgments. Nonetheless, findings that articulate the nexus—residence plus ongoing trafficking, or a curbside transaction with re-entry—create a solid appellate record.

Complex Concepts Simplified

Probable cause. A practical, common-sense standard: is there a fair probability that evidence of a crime will be found in the place to be searched? It does not require proof beyond a reasonable doubt or elimination of all innocent explanations.
Nexus. The required link between the place to be searched (here, a home) and the evidence sought. In drug cases, courts often infer a nexus when ongoing dealing and residence are both shown.
Known drug dealer doctrine. In the Sixth Circuit, an affidavit showing (1) the suspect’s residence and (2) ongoing, continual trafficking supports an inference that evidence will be found at home—even without direct evidence of dealing at that address.
Curbside transaction rule. Observing a drug deal at or just outside a home, followed by the suspect’s immediate return inside, typically suffices to search the residence due to the natural inference that contraband/records are stored there.
Substantial-basis review and deference. Appellate courts give “great deference” to the issuing judge’s probable cause determination and review for whether there was a substantial basis for the decision, not whether the appellate court would have issued the warrant in the first instance.
Four-corners principle. The sufficiency of an affidavit is assessed based on its contents, not on external information or hypothetical additions. Challenges must engage with what the affidavit actually says.

Conclusion

United States v. Long cements, and modestly extends, the Sixth Circuit’s robust approach to the residence-evidence nexus in drug investigations. It confirms that when officers credibly establish that a suspect is engaged in ongoing trafficking and that the place to be searched is the suspect’s residence—especially when residence is admitted in supervision records—probable cause is ordinarily present. It also reaffirms that even a single hand-to-hand transaction outside a residence, followed by the suspect’s return indoors, can itself support a home search. While the majority articulates these as separate, independently sufficient paths, the concurrence reminds courts and practitioners that the constitutional test remains the totality of the circumstances. Together, the opinions provide clear guidance to law enforcement, litigants, and magistrate judges on how to build, challenge, and evaluate search-warrant affidavits in narcotics cases and beyond.