Good-Faith Reliance Saves a Warrant with a Potential Street-Name Error When Officers Use Official Records and Know the Target Location

1. Introduction

In United States v. Davis (10th Cir. Apr. 16, 2026), the Tenth Circuit addressed a suppression challenge arising from an alleged address defect in a search warrant. Sheriff’s deputies searched Michael Shaun Davis’s home pursuant to a warrant and found firearms and ammunition that, as a convicted felon, he could not lawfully possess under 18 U.S.C. § 922(g)(1).

The key dispute was narrow but consequential: the warrant authorized a search of “10 McGinnis Street,” while Davis contended the correct street name was “10 Meginnis Street.” The warrant otherwise contained no descriptive identifiers (e.g., color, landmarks, physical description). Davis argued that this purported street-name error rendered the warrant invalid under the Fourth Amendment’s particularity requirement and required suppression of the evidence.

The Tenth Circuit affirmed, holding that—even assuming the warrant listed the incorrect street—law enforcement relied on the warrant in good faith, so suppression was unwarranted.

2. Summary of the Opinion

  • The court declined to decide whether the warrant satisfied the Fourth Amendment’s particularity requirement.
  • Instead, it affirmed on the alternative ground that the good-faith exception to the exclusionary rule applied.
  • The court emphasized the absence of “culpable” police conduct: the warrant affiant used county assessor records to determine the address, and at least one executing deputy testified he “knew exactly” where Davis lived because he had been there before.
  • The court rejected Davis’s argument that the warrant was so facially deficient that no reasonable officer could rely on it.
  • The court distinguished United States v. Williamson, where officers searched premises bearing an entirely different address and the warrant’s address corresponded to a mailbox miles away.
  • The court held that a new “improper execution” theory raised for the first time in the reply brief was waived under United States v. Leffler.

3. Analysis

A. Precedents Cited

1) United States v. Russian

United States v. Russian, 848 F.3d 1239 (10th Cir. 2017), supplied the doctrinal framing in two ways:

  • Particularity baseline: “The Fourth Amendment demands that a search warrant describe the place to be searched with particularity.”
  • Good-faith pathway: Even if a warrant ultimately violates particularity, evidence is not suppressed when officers act in objectively reasonable reliance on the warrant.

Davis follows Russian’s pragmatic focus: the suppression question turns less on technical defect-labeling and more on whether officers behaved reasonably and whether exclusion would deter misconduct.

2) United States v. Suggs and United States v. Leon

United States v. Suggs, 998 F.3d 1125 (10th Cir. 2021), is cited for the general proposition that Fourth Amendment violations typically trigger suppression in the government’s case-in-chief. But the controlling exception is rooted in United States v. Leon, 468 U.S. 897 (1984), which created the modern good-faith exception.

Leon matters here for two specific rules:

  • Default: suppression is a remedy for unlawful searches.
  • Limit: suppression is not warranted when officers reasonably rely on a warrant later found invalid.
  • Facial deficiency carve-out: good faith does not apply when a warrant is “so facially deficient” that officers cannot reasonably presume it to be valid.

Davis is essentially an application of Leon’s “facially deficient” boundary: the court held this warrant did not cross that line even if the street name was misspelled or disputed.

3) Herring v. United States

Herring v. United States, 555 U.S. 135 (2009), deepened the deterrence logic behind Leon by tying suppression to police culpability and deterrent value. The Davis panel quoted Herring’s core standard: exclusion requires conduct “sufficiently deliberate” and “sufficiently culpable” such that deterrence is worth the systemic cost.

In Davis, the court found no such culpability: the address came from official county records, and an executing officer already knew the correct house—facts that diminish any claim of reckless or grossly negligent police behavior.

4) United States v. Williamson

Davis’s central attempt to avoid good faith relied on United States v. Williamson, 1 F.3d 1134 (10th Cir. 1993), where the court denied good faith because the warrant provided “no meaningful description of the premises” and officers searched locations bearing addresses entirely different from the warrant’s address.

The Davis panel distinguished Williamson on practical grounds:

  • Magnitude of mismatch: Williamson involved searching premises with a wholly different address; the warrant’s address corresponded to a mailbox at least eight miles away.
  • Nature of alleged defect: Davis involved a close spelling dispute (McGinnis vs. Meginnis) compounded by uncertainty about “taxable address” versus “physical address,” not a remote or unrelated location.

5) United States v. Leffler

The panel invoked United States v. Leffler, 942 F.3d 1192 (10th Cir. 2019), to enforce appellate issue-preservation rules. Davis attempted in his reply brief to argue improper execution of the warrant; the court held that waiting until the reply brief waived the argument.

This procedural holding is a reminder that suppression litigation is often won or lost on timely, developed theories supported by record evidence.

6) Vincent v. Bondi (Second Amendment issue)

Davis also challenged § 922(g)(1) under the Second Amendment, but the court rejected it as foreclosed by Vincent v. Bondi, 127 F.4th 1263 (10th Cir. 2025). While not central to the warrant issue, this indicates the panel treated the constitutional merits of the firearm-disability statute as settled within the circuit.

B. Legal Reasoning

The court’s reasoning proceeds in a disciplined sequence aligned with modern Fourth Amendment remedial doctrine:

  1. Choose the narrower dispositive ground: Rather than definitively resolve whether the address discrepancy violated the particularity requirement, the panel assumed arguendo that the street name was wrong and decided the case on good faith.
  2. Apply de novo review to good faith and assess the “totality of the circumstances”: Citing United States v. Russian, the panel reviewed good faith de novo, considering the entire record in the light most favorable to the government.
  3. Assess culpability and deterrence under Herring: The panel found no police behavior that suppression would deter—especially because:
    • the investigator used county assessor records to identify the address, and
    • an executing deputy testified he “knew exactly” where Davis lived due to prior visits.
  4. Reject “facially deficient warrant” characterization under Leon: The panel emphasized that even after an evidentiary hearing, the district court could not determine definitively whether the warrant’s street name was wrong; therefore, it would be “odd” to say any reasonable officer would have known it was wrong based on less information at the time of execution.
  5. Address the practical navigation argument: Davis argued that an officer would have discovered the error when trying to find the house (e.g., via Google Maps). The panel found the record undeveloped about street signage and noted officers had no reason to consult mapping tools because at least one deputy already knew the location.
  6. Distinguish contrary precedent (Williamson): The mismatch in Williamson was severe and objectively obvious; the alleged defect here was not.
  7. Enforce waiver: The improper-execution theory raised in the reply brief was waived under United States v. Leffler.

C. Impact

Although labeled an “ORDER AND JUDGMENT” and “not binding precedent,” the decision is likely to be cited for persuasive value in suppression disputes involving address irregularities. Its practical impacts include:

  • Address imperfections and “context-dependent” addressing: Where official records (e.g., county assessor databases) support the warrant address and local addressing can vary (taxable vs. physical), courts may be more inclined to treat the issue as one of good-faith reliance rather than per se invalidity.
  • Officer familiarity can bolster good faith: Testimony that executing officers already knew the correct premises can reduce the likelihood that an address discrepancy will be treated as rendering the warrant “facially deficient.”
  • Record development matters: The panel’s discussion highlights how the absence of evidence about street signs, mailboxes, or other on-the-ground identifiers can weaken a defendant’s argument that the defect was obvious.
  • Litigation discipline: Suppression arguments must be raised timely and supported with proof; new theories first presented in reply briefs risk waiver.

4. Complex Concepts Simplified

Particularity requirement (Fourth Amendment)
A search warrant must identify the place to be searched clearly enough that officers can locate it and avoid searching the wrong place.
Exclusionary rule
A judge-made remedy that generally keeps evidence obtained through unconstitutional searches out of the government’s main case at trial.
Good-faith exception
Even if a warrant turns out to be legally defective, evidence will not be suppressed if officers acted in objectively reasonable reliance on the warrant—because excluding the evidence would not meaningfully deter misconduct.
“So facially deficient” (Leon)
A limit on good faith: if a warrant is obviously inadequate on its face (for example, it fails to meaningfully identify the place to be searched), officers cannot reasonably rely on it.
Waiver on appeal
Appellate courts generally will not consider arguments raised for the first time in a reply brief, because the opposing party had no fair chance to respond and the issue was not properly presented.

5. Conclusion

United States v. Davis reinforces a central theme of modern suppression doctrine: courts will focus on culpability and deterrence, not merely on technical imperfections. Even if a warrant arguably misspells or misstates a street name—and even if the warrant lacks additional physical descriptors—suppression may be denied where officers rely on official address records and the executing officers can identify the correct target location, making their reliance objectively reasonable under United States v. Leon and Herring v. United States. The decision also serves as a procedural caution: suppression theories must be raised early and supported by a developed record, or they may be deemed waived under United States v. Leffler.