Precedents Cited

1) The Fourth Amendment, probable cause, and nexus

• Mincey v. Arizona: Cited for the foundational principle that searching a home generally requires a warrant supported by probable cause.
• United States v. Mora: Provided the Tenth Circuit’s articulation of probable cause (a “fair probability” that evidence will be found in a particular place) and emphasized that nexus depends on the “strength of the case-specific evidence” linking the home to suspected criminal activity.
• United States v. Rowland and United States v. Corral-Corral: Used to underscore that probable cause requires a nexus between suspected criminal activity and the place to be searched.
• United States v. Biglow: Reinforced the nexus requirement within the Tenth Circuit’s probable-cause framework.

2) The exclusionary rule’s purpose and the deterrence principle

• United States v. Herrera: Cited for the general remedial premise—suppression ordinarily follows a Fourth Amendment violation.
• United States v. Knox and Davis v. United States: Anchored the deterrence rationale: suppression is meant to deter future violations, and courts weigh deterrence benefits against substantial costs.

3) The good-faith exception and its limits

• United States v. Leon: The controlling doctrine—evidence seized under a warrant later found unsupported by probable cause may still be admitted if officers acted in objectively reasonable reliance on the warrant. The opinion also relies on Leon’s “so lacking in indicia of probable cause” standard.
• United States v. Edwards and United States v. Russian: Used to define objective reasonableness and reinforce that good faith can apply even when the probable-cause logic is imperfect, so long as it is not obviously unsound.
• United States v. Cardall: Supplied the “presumption” that reliance on a magistrate-issued warrant is in good faith.
• Messerschmidt v. Millender: Elevated the threshold for defeating good faith, focusing on whether the magistrate’s error was so obvious that any reasonable officer would recognize it.
• United States v. Henderson and United States v. Campbell: These are central to the “minimal nexus” concept: an affidavit can be sufficient for good faith if it provides a minimally sufficient connection between criminal activity and the place to be searched, even without “hard evidence” directly tying the home to the crime.
• United States v. Cordova and United States v. Roach: Distinguished “bare bones” affidavits—those containing only suspicions, beliefs, or conclusions—from affidavits that, while insufficient for probable cause, still provide some factual basis to support good-faith reliance.
• United States v. Burgess: Invoked to support the idea that procedural compliance throughout an investigation is a marker of good faith.

4) The opinion’s focal comparators: Gonzales vs. Cotto

• United States v. Gonzales: The defense’s primary comparator. The Tenth Circuit in Gonzales rejected good faith because the affidavit offered no facts connecting the residence to the defendant or suspected criminal activity; it relied largely on the generalized assertion that firearms are often kept at residences. In Williams, the court distinguished Gonzales by identifying concrete facts linking the Jeep, the home, and Williams’s residence.
• United States v. Cotto: The Government’s primary comparator. Cotto accepted good faith where a suspect’s car connected to the crime was found parked at a residence, and the suspect was arrested there. Williams aligned its reasoning with Cotto: the Jeep contained evidence of the suspected offense, and it was later observed at the residence to be searched.

5) “Bare bones” examples used to define the floor

• Nathanson v. United States and Aguilar v. Texas (abrogated by Illinois v. Gates): Cited through Leon to illustrate affidavits that merely assert belief or suspicion without supporting facts—what the Tenth Circuit treats as “bare bones.”

6) Additional guidance (persuasive or out-of-circuit)

• United States v. Jimenez (unpublished): Offered for persuasive value and used to show that surveillance tying a suspect (and the relevant vehicle) to a residence can support good faith.
• United States v. Gilbert (6th Cir.): Quoted for the conceptual “daylight” between “substantial basis” (probable cause) and “bare bones” (no good faith), reinforcing the intermediate “minimal nexus” zone where good faith can operate.
• United States v. Lewis and United States v. White (6th Cir.): Cited to emphasize that an affidavit is not “bare bones” merely because probable cause is lacking; some modicum of evidence connecting the crime to the place can be enough for good-faith reliance.

7) Waiver doctrine shaping the scope of review

• United States v. Leffler: The court agreed the Government waived a probable-cause theory by not raising it below and not arguing plain error on appeal. This waiver mattered because it nudged the panel to focus narrowly on good faith and avoid expanding probable-cause doctrine on the facts presented.

Legal Reasoning

The panel’s reasoning tracks the canonical Leon framework as filtered through Tenth Circuit “minimal nexus” doctrine:

1. Start with a presumption of good faith once a neutral magistrate issues a warrant. Relying on United States v. Cardall and Messerschmidt v. Millender, the court treats magistrate approval as creating a strong presumption that officers acted reasonably—particularly when the record shows procedural compliance and no “scope creep” in execution.
2. Ask whether the affidavit is “bare bones” (so deficient that reliance is objectively unreasonable). Using United States v. Cordova, United States v. Roach, and United States v. Leon, the court looks for whether the affidavit contains only conclusions or, instead, contains factual circumstances supporting a connection to the place searched.
3. Apply the “minimal nexus” standard rather than the full probable-cause standard. Citing United States v. Henderson and United States v. Campbell, the court clarifies that good faith can apply even where the affidavit falls short of probable cause, so long as it offers enough factual support to make reliance reasonable.
4. Resolve the close call by comparison to fact-pattern benchmarks. The opinion positions United States v. Gonzales as the “no nexus at all” case and United States v. Cotto as a “some nexus” case. Because Williams’s affidavit contained (a) evidence located in the Jeep, (b) observation of the Jeep at the residence, and (c) information that Williams lived at the residence, the panel treated it as closer to Cotto than Gonzales.
5. Confirm that existing Tenth Circuit law did not clearly foreclose reliance. The opinion adds a “notice” check (from United States v. Henderson): even if there is some factual support, officers cannot rely on a warrant when they “know or should have known” it is invalid based on functionally identical precedent. The panel stressed that the Tenth Circuit had not resolved whether “a suspect’s parked car outside a home, without more,” suffices for probable cause; therefore, officers were not on clear notice that the warrant was invalid.

In short, Williams does not hold that the affidavit established probable cause; it holds that the affidavit was not so facially deficient that reliance on the magistrate’s authorization became “entirely unreasonable.”

Impact

Even as a nonprecedential disposition, United States v. Williams is a practical signal about how the Tenth Circuit is likely to treat suppression disputes involving a thin “home nexus,” especially where (1) police previously found crime-related items in a vehicle and (2) later observed that vehicle at the suspect’s residence. The opinion’s impact is best understood in three dimensions:

• Operational impact on warrant practice: Investigators may view the “vehicle + residence observation” fact pattern as a safer basis for seeking residential warrants under the good-faith umbrella, even when direct evidence that the home contains contraband is limited.
• Litigation impact on suppression motions: Defendants challenging nexus may face a two-layer hurdle: (a) contest probable cause and (b) separately show the affidavit was “bare bones” such that reliance was objectively unreasonable. Williams reinforces how difficult it is to win at layer (b) when the affidavit contains any case-specific linking facts.
• Doctrinal impact on the “daylight” between probable cause and bare bones: By quoting United States v. Gilbert and leaning on United States v. Roach, the panel underscores that good faith occupies a meaningful middle space—encouraging courts to avoid collapsing “no probable cause” into “automatic suppression.”

The opinion also indirectly encourages careful appellate preservation: the Government’s waiver (under United States v. Leffler) narrowed review to good faith, illustrating how forfeiture can prevent appellate courts from developing (or rescuing) a probable-cause theory.