Observed Trash Pulls, Digital Evidence, and the Nexus Requirement: A Commentary on United States v. Hawkins (6th Cir. 2025)

Observed Trash Pulls, Digital Evidence, and the Nexus Requirement: A Commentary on United States v. Hawkins (6th Cir. 2025)

I. Introduction

United States v. Shedrick Hawkins, No. 24-3839 (6th Cir. Nov. 19, 2025) (not recommended for publication), is a significant application—and quiet consolidation—of the Sixth Circuit’s evolving Fourth Amendment jurisprudence on probable cause and the “nexus” requirement for residential search warrants.

The case arises from a Franklin County (Ohio) narcotics investigation into James Crockett, a suspected drug trafficker. In the course of that investigation, officers tied Crockett’s source of supply to a phone number (PN5022), a maroon Nissan Maxima, and ultimately to an apartment at 314 Highview Landing occupied by defendant-appellant Shedrick Hawkins. After:

  • a controlled buy from Crockett,
  • surveillance of multiple vehicles associated with Hawkins and a car dealership,
  • cellphone “ping” evidence linking PN5022 to Hawkins’s movements,
  • Facebook messages about drugs between Hawkins and Crockett, and
  • a “trash pull” where officers watched Hawkins discard trash bags later found to contain drug residue,

officers obtained a search warrant for Hawkins’s residence. The search yielded large quantities of fentanyl and cocaine, four firearms, cash, and paraphernalia. Hawkins moved to suppress, arguing that the warrant lacked probable cause and, more specifically, that the affidavit failed to establish a sufficient nexus between his apartment and evidence of drug trafficking.

The Sixth Circuit affirmed the denial of the motion to suppress. In doing so, it:

  • reaffirmed that a trash pull, when officers see the suspect discard the trash and when combined with corroborating drug-trafficking evidence, creates probable cause to search a home, and
  • clarified that officers need not observe drug sales at the residence itself so long as there is a “fair probability”—a “fair shot”—that contraband will be found there under a holistic, totality-of-the-circumstances analysis.

II. Factual and Procedural Background

A. The Crockett investigation and initial controlled buy

The investigation began in April 2023, when the Franklin County Sheriff’s Office Special Investigations Unit received a complaint that James Crockett was selling drugs in Columbus. The complaint included Crockett’s Facebook profile. Detective Christina Goble contacted Crockett via Facebook Messenger and arranged a series of controlled buys.

On May 9, 2023, an undercover detective (UD) arranged to purchase one ounce of cocaine from Crockett. When the UD arrived, Crockett:

  • asked to be driven to pick up the drugs;
  • contacted several individuals, including the holder of number PN5022;
  • agreed to meet PN5022 at a new location; and
  • upon arrival, entered a maroon Nissan Maxima, stayed about five minutes, and exited with a bag containing a white powder later confirmed as cocaine.

The UD paid $700, completing the controlled buy. Officers, observing this, began surveillance of the Maxima and followed it to the Highview Landing apartment complex, where it went to 327 Highview Landing.

A registration check showed the Maxima was owned by Spectrum Motor 1 LLC. A cellphone “ping” warrant for PN5022 indicated that the phone was in the same area as the Maxima during the sale, linking PN5022, the Maxima, and the drug transaction.

B. Connecting PN5022, vehicles, and Hawkins to 314 Highview Landing

A few days later, Detective Goble obtained a warrant to place a GPS tracker on the Maxima, which she located near 314 Highview Landing. The vehicle was later moved to Spectrum’s car lot and remained there from May 20–23.

On May 23, Goble conducted further surveillance at 314 Highview Landing and observed:

  • a Dodge Charger in the same spot previously occupied by the Maxima;
  • registration records showing the Charger was registered to Hawkins, and that Hawkins lived at 314 Highview Landing;
  • a white Dodge Durango registered to Spectrum; and
  • a silver Chevrolet Malibu registered jointly to Hawkins and Spectrum.

Hawkins’s Facebook profile included a photo of him standing in front of a white Dodge Durango resembling the one seen at 314 Highview Landing.

C. Digital evidence: Facebook messages and cellphone pings

On May 26, a municipal judge issued a warrant to search Crockett’s cellphone. That search revealed Facebook messages between Crockett and Hawkins:

  • sharing videos of marijuana;
  • discussing drug prices; and
  • discussing meeting locations.

The affidavit did not specify quantities or the full extent of their communications, but they strengthened the inference of an ongoing drug-trafficking relationship.

On the same day, Goble observed Hawkins leave his apartment at 314 Highview Landing. At that time, PN5022’s location data showed movements consistent with Hawkins’s movement, further linking the phone to him and to that residence.

D. The observed trash pull and suspected Taylor Avenue transaction

On June 5, Goble:

  • observed Hawkins exit 314 Highview Landing carrying a pink trash bag and a white bag with red lettering;
  • watched him discard both in a community dumpster on the property; and
  • immediately retrieved those same distinctive bags with another detective; no other similar bags were in the dumpster.

Inside, officers found a clear plastic bag containing residue of a white powder. Lab testing confirmed the residue was cocaine, fentanyl compound, or methamphetamine.

The next day (June 6), Goble saw Hawkins leave the vicinity of 314 Highview Landing in a white Ford Explorer and drive to 2351 Taylor Avenue. An unknown male came out, approached the Explorer’s front passenger window, and—after about two minutes—walked away carrying a brown bag. Goble, based on her training and experience, characterized this brief, curbside exchange as a suspected drug transaction. Hawkins then drove directly back to 314 Highview Landing.

E. The search warrant, seizure, and district court ruling

Based on:

  • the controlled buy with Crockett;
  • the linkage of PN5022 and the Maxima to that buy;
  • vehicle records tying multiple cars, including the Maxima’s parking place, to 314 Highview Landing and to Hawkins;
  • Facebook drug-related messages between Hawkins and Crockett;
  • cellphone pings tracking PN5022 consistently with Hawkins’s movements;
  • the observed trash pull that immediately yielded drug residue; and
  • Hawkins’s trip from 314 Highview to the apparent Taylor Avenue handoff and straight back home,

Detective Goble sought and obtained a warrant to search Hawkins’s residence at 314 Highview Landing for evidence of drug trafficking.

Executing the warrant, officers seized:

  • four firearms;
  • 1,197 grams of fentanyl;
  • 1,806 grams of cocaine;
  • approximately $17,775 in cash;
  • drug paraphernalia; and
  • firearm magazines and ammunition.

Hawkins was indicted for:

  • Count One: possession with intent to distribute 400+ grams of fentanyl and 500+ grams of cocaine, 21 U.S.C. §§ 841(a)(1), 841(b)(1)(A)(vi), 841(b)(1)(B)(ii); and
  • Count Two: felon in possession of a firearm, 18 U.S.C. §§ 922(g)(1), 924(a).

He moved to suppress the evidence seized from his residence, arguing that:

  • the warrant lacked probable cause, and
  • the affidavit failed to establish the required nexus between his residence and the contraband sought.

The district court denied the motion, holding that “the totality of the circumstances established a strong nexus” between the apartment and illegal drugs. Because it found probable cause, it did not address the good-faith exception.

Hawkins entered a conditional guilty plea to both counts, reserving the right to appeal the suppression ruling. He received concurrent sentences of 135 months’ imprisonment and concurrent terms of supervised release (five years on Count One, three years on Count Two). He then appealed.

III. Summary of the Sixth Circuit’s Opinion

The Sixth Circuit affirmed the denial of the motion to suppress. Applying the traditional Fourth Amendment standard, the court held that:

  • probable cause existed to support the warrant to search Hawkins’s residence, and
  • the affidavit established a sufficient nexus between the residence and evidence of drug trafficking.

The panel emphasized:

  • The standard for probable cause “is not a difficult standard to meet” (quoting United States v. Whitlow).
  • The controlling question is whether there is a “fair probability that contraband or evidence of a crime will be found in a particular place” (quoting United States v. Grubbs and United States v. Sanders (en banc)).
  • The analysis is holistic and based on the “totality of the circumstances,” not a hypertechnical or line‑by‑line dissection of individual affidavit paragraphs.

Specifically, the court held that:

  • Trash‑pull evidence establishing drug residue from Hawkins’s trash, observed as he discarded it, combined with corroborating evidence of drug trafficking, sufficed to create probable cause to search his home.
  • Corroborating evidence included:
    • Hawkins’s apparent role in Crockett’s supply chain for the controlled buy;
    • cellphone pings matching Hawkins’s movements;
    • Facebook messages about drug prices, marijuana, and meetings;
    • the pattern of vehicles associated with Hawkins and Spectrum cycling through the same parking spot; and
    • Hawkins traveling from his home to a suspected hand‑to‑hand transaction and back.
  • Officers were not required to see Hawkins selling drugs from his apartment or to have “ironclad evidence” of contraband inside, only a “fair shot of finding contraband” there (quoting United States v. Higgins).
  • The affidavit did not impermissibly rely on Goble’s “training and experience” to “fill in” factual gaps; rather, it used her experience appropriately to characterize observed conduct that already had a concrete evidentiary basis.

Because the warrant was supported by probable cause, the panel declined to reach the government’s alternative argument that the good-faith exception would apply.

IV. Precedents and Doctrinal Context

A. Standard of review and deference to issuing judges

The opinion begins by situating its standard of review:

  • Factual findings from the suppression hearing are reviewed for clear error (United States v. Frazier, 423 F.3d 526 (6th Cir. 2005)).
  • Legal conclusions, including whether probable cause exists as a matter of law, are reviewed de novo.

Importantly, even though the appellate court reviews the existence of probable cause de novo, it must give “great deference” to the issuing judge’s original determination. As United States v. Washington, 380 F.3d 236 (6th Cir. 2004), quoting United States v. Leake, 998 F.2d 1359 (6th Cir. 1993), explains, those findings should not be set aside unless the issuing judge “arbitrarily exercised” his or her authority.

United States v. Brown, 732 F.3d 569 (6th Cir. 2013), is cited to underscore that this deference runs to the issuing judge, not to the district court’s subsequent review. On appeal, the court owes “no particular deference” to the district court’s legal conclusions about probable cause.

B. Probable cause and the “nexus” requirement

The controlling doctrinal framework comes from several cases:

  • United States v. Carpenter, 360 F.3d 591 (6th Cir. 2004) (en banc) and United States v. Van Shutters, 163 F.3d 331 (6th Cir. 1998):
    • These decisions define the need for a nexus—a reasonable link—between “the place to be searched and the evidence sought.”
  • United States v. Grubbs, 547 U.S. 90 (2006):
    • Articulates the “fair probability that contraband or evidence of a crime will be found in a particular place” standard, which is the core test for probable cause.
  • United States v. Sanders, 106 F.4th 455 (6th Cir. 2024) (en banc):
    • An important recent en banc decision reaffirming that probable cause is a “not a difficult standard to meet” and warning courts not to require an “actual showing” of criminal activity at the targeted location.
    • Instead, officers may rely on direct or circumstantial evidence that creates “more than mere suspicion” that contraband will be found there.
    • Emphasizes a holistic, totality-of-the-circumstances approach, rejecting hypertechnical, line‑by‑line dissection of affidavits.
  • United States v. Berry, 565 F.3d 332 (6th Cir. 2009):
    • Limits the probable cause analysis to the “four corners” of the affidavit, preventing post hoc rationalizations or supplementation.
  • United States v. Whitlow, 134 F.4th 914 (6th Cir. 2025):
    • Quoted here for the proposition that probable cause is “not a difficult standard to meet.”

Together, these precedents frame the Hawkins analysis: the panel asks whether, on the four corners of Goble’s affidavit, there was a fair probability that evidence of drug trafficking would be found at 314 Highview Landing, giving substantial deference to the municipal judge’s decision to issue the warrant.

C. Trash-pull jurisprudence: United States v. Abernathy

United States v. Abernathy, 843 F.3d 243 (6th Cir. 2016), is the key comparator case. In Abernathy, officers conducted a trash pull outside the defendant’s home and recovered a marijuana stem and a small quantity of loose marijuana. The Sixth Circuit held that:

  • the trash‑pull evidence alone did not establish probable cause to search the home; and
  • the record lacked:
    • evidence that officers observed the defendant discarding the trash, or
    • any corroborating evidence tying the defendant to ongoing drug trafficking.

The Hawkins court:

  • acknowledges Abernathy’s holding that “drugs found in a trash pull outside the defendant’s house were insufficient, standing alone, to create probable cause to search [the] Defendant’s residence.”
  • emphasizes the crucial phrase “standing alone,” and
  • highlights Abernathy’s own distinction between:
    • cases where the trash pull is the only evidence, and
    • cases where the trash pull is corroborated by other indicia of drug trafficking.

In Abernathy, the court criticized the affidavit because officers:

  • did not see who placed the trash at the curb,
  • could not say with confidence the contraband came from the defendant’s home, and
  • could not tell how recently drugs had been in the home—weakening any inference that drugs were still there.

By contrast, in Hawkins:

  • Goble personally watched Hawkins carry two distinctive bags from his apartment to the dumpster and immediately retrieved those same bags; and
  • the affidavit was replete with corroborating evidence of Hawkins’s ongoing involvement in drug trafficking.

Thus, Hawkins does not undercut Abernathy; it applies Abernathy’s own logic: a trash pull observed to be tied directly to the suspect’s residence and accompanied by significant corroborating evidence does create probable cause.

D. Additional supportive precedents

1. Marcilis v. Township of Redford, 693 F.3d 589 (6th Cir. 2012)

In Marcilis, the Sixth Circuit held that probable cause existed to search residences where:

  • a trash pull recovered torn plastic bags testing positive for cocaine and marijuana,
  • officers observed multiple suspected drug transactions involving the plaintiff, and
  • the suspect made trips to the residences during these transactions.

Hawkins fits neatly within this pattern: observed suspected transactions, travel between the drug transaction sites and the residence, and drug‑related trash.

2. United States v. Talley, 692 F. App’x 219 (6th Cir. 2017)

In Talley, probable cause to search a residence was found where:

  • a trash pull uncovered a small amount of marijuana,
  • officers had smelled unburnt marijuana at the home days earlier, and
  • the suspect had a history of drug trafficking.

The Hawkins court cites Talley to demonstrate the Sixth Circuit’s consistent willingness to infer probable cause from a modest amount of physical evidence in the trash when combined with other indicators of drug involvement.

3. United States v. Higgins, 141 F.4th 811 (6th Cir. 2025)

Higgins is quoted in Hawkins for several notable propositions:

  • Officers need not “observe [the defendant] selling from his apartment” to establish probable cause to search that apartment.
  • They do not need “ironclad evidence that contraband will be present” before executing a search warrant.
  • The question is whether there is “a fair shot of finding contraband” at the residence.

Hawkins uses these formulations to reject Hawkins’s argument that the lack of controlled buys or observed sales at 314 Highview Landing defeated the nexus requirement.

4. United States v. Allen, 211 F.3d 970 (6th Cir. 2000) (en banc)

Allen is cited for the principle that a warrant affidavit is evaluated “on the adequacy of what it does contain, not on what it lacks, or on what a critic might say should have been added.” This admonition bolsters the court’s refusal to discount the affidavit merely because it lacked certain details (e.g., precise drug quantities in the Facebook messages).

5. United States v. Schultz, 14 F.3d 1093 (6th Cir. 1994) & United States v. Williams, 544 F.3d 683 (6th Cir. 2008)

These cases address the permissible role of an officer’s “training and experience” in probable cause determinations:

  • Courts may consider an officer’s experience in inferring the significance of otherwise ambiguous facts.
  • However, training and experience cannot substitute for a lack of an evidentiary nexus; they are not enough standing alone.

Hawkins uses these authorities to approve Goble’s reliance on her training to characterize the brief Taylor Avenue encounter as a suspected narcotics transaction, while emphasizing that there was abundant objective evidence of drug activity independent of that characterization.

6. United States v. Dyer, 580 F.3d 386 (6th Cir. 2009)

Finally, Dyer is cited for a procedural point: once a court finds the warrant was supported by probable cause, it need not reach whether the good‑faith exception would have saved the evidence anyway. The Hawkins court follows that approach.

V. The Court’s Legal Reasoning in Hawkins

A. Establishing the nexus: how the facts fit the standard

The core question was whether the affidavit established a fair probability that evidence of drug trafficking would be found at Hawkins’s residence. The court identified multiple converging lines of evidence, many of which the district court summarized in nine points:

  1. Crockett contacted the user of PN5022 to buy drugs for the controlled buy with the undercover officer.
  2. PN5022 had multiple cellphone pings at 314 Highview Landing during police surveillance.
  3. Crockett obtained cocaine from the driver of the Maxima.
  4. After the May 9 controlled buy, the Maxima drove to the Highview Landing complex (327 Highview) and was later found parked at 314 Highview.
  5. Multiple cars—including the Maxima—rotated in and out of the same parking spot at 314 Highview over a few days, behavior consistent (per officer experience) with drug traffickers who frequently change vehicles and use third‑party registrations.
  6. Hawkins was the registered owner of at least three of those four cars (the Charger, the Malibu co‑registered with Spectrum, and another vehicle).
  7. Facebook communications between Crockett and Hawkins discussed drug prices, meeting locations, and shared pictures/videos of marijuana.
  8. Hawkins left 314 Highview, drove to another house (Taylor Avenue), engaged in what appeared to be a short‑duration handoff of a brown bag, and immediately returned to his apartment—behavior consistent with a drug delivery.
  9. Cellphone pings for PN5022 tracked Hawkins’s movements, supporting the inference that Hawkins used that phone in connection with drug activity.

Superimposed on all of that was the critical trash‑pull evidence:

  • Goble personally watched Hawkins carry the pink and white bags from 314 Highview to the community dumpster.
  • Officers immediately recovered those same unique bags.
  • The bags contained a clear plastic bag with residue testing positive for cocaine, fentanyl compound, or methamphetamine.

The court characterized this as exactly the sort of “direct or circumstantial support” Sanders contemplates: more than mere suspicion that contraband would be found at Hawkins’s home. The trash-pull evidence, in combination with the pattern of conduct and digital communications, firmly tied Hawkins, his residence, and his vehicles to ongoing drug trafficking.

B. Distinguishing Abernathy and reinforcing trash-pull doctrine

Hawkins’s central doctrinal argument—that the presence of drug residue in trash did not establish a nexus to the home—draws from Abernathy. The court responded by:

  • accepting Abernathy’s rule that a trash pull “standing alone” may be insufficient;
  • stressing that here the officers saw Hawkins discard the trash, eliminating the uncertainty present in Abernathy about the trash’s origin and timing; and
  • highlighting the wealth of corroborating evidence of drug trafficking that Abernathy lacked.

In Abernathy, the court emphasized that officers could not tell:

  • whether the drugs in the trash even came from the defendant’s residence; or
  • if they had, whether the drugs had been in the residence recently—key to inferring that drugs remained there.

In Hawkins, those concerns are neutralized:

  • Goble observed Hawkins place the trash seemingly straight from his apartment into the dumpster.
  • The retrieval was immediate, ensuring recency.
  • Additional evidence (vehicles, phone pings, online communications, observed suspected transaction) independently confirmed ongoing drug activity.

The opinion expressly notes that Abernathy itself distinguished cases where:

  • trash‑pull evidence was accompanied by other corroborating indicators, or
  • the quantity or nature of evidence in the trash was stronger.

Hawkins thus fits within the pro‑probable‑cause side of the trash‑pull line of cases, reinforcing a pragmatic rule: an observed trash pull showing drug residue, coupled with corroborating evidence of drug activity, is enough to search a home.

C. Role of officer training and experience

Hawkins argued that Detective Goble improperly relied on her “training and experience” to infer that the Taylor Avenue encounter was a drug transaction, effectively “filling in” gaps in crucial facts.

The court responded by:

  • reaffirming that courts may give “considerable weight” to the conclusions of experienced officers about where evidence of a crime is likely to be found (Schultz, Williams);
  • reiterating that training and experience cannot substitute for an evidentiary nexus, but can help interpret the significance of observed facts; and
  • finding that, in this case, there was no lack of evidentiary nexus—the affidavit was rich with facts independent of Goble’s professional judgment about the Taylor Avenue interaction.

Thus, Goble’s references to her training—both about drug traffickers’ use of multiple vehicles and brief public handoffs—were treated as explanatory context for already‑concrete observations, not as speculative leaps.

D. Rejection of Hawkins’s specific arguments

1. “No sales occurred at my apartment”

Hawkins contended that, while officers might have had probable cause to arrest him or to believe he used drugs, they lacked a nexus to his residence because:

  • they did not observe sales or controlled buys at 314 Highview Landing, and
  • nothing proved that additional drugs were still inside the apartment.

Citing Higgins, the court held:

  • Officers are not required to witness drug sales occurring at the residence itself.
  • The law does not require “ironclad evidence” that contraband will be present before issuance of a warrant.
  • The correct question is whether there is a “fair shot” of finding drugs or evidence there under the totality of the circumstances.

Under that standard, the combination of the trash pull, the movements between the residence and the suspected transaction site, the vehicle patterns, the phone pings, and the social‑media evidence created at least a fair probability, and that is enough.

2. “Training and experience filled critical gaps”

Hawkins also argued that Goble’s use of her “training and experience” in describing the Taylor Avenue interaction and the vehicle patterns improperly filled gaps in factual proof.

The court rejected this argument on two grounds:

  • Legally, it is well‑established that courts may consider an officer’s training and experience in evaluating probable cause, so long as there is a factual basis to which that experience is applied.
  • Factually, the affidavit contained a robust evidentiary basis for inferring drug trafficking even if one discounted Goble’s expertise regarding the Taylor Avenue stop.

Thus, training and experience here were additive, not dispositive.

VI. Impact and Significance

A. For law enforcement: building residential probable cause

Hawkins confirms several operational lessons for investigators in the Sixth Circuit:

  • Observed trash pulls are powerful: When officers personally see a suspect discard trash and quickly recover it, drug residue in that trash is strong evidence that contraband was recently in the home.
  • Corroboration matters: Investigators should aim to combine trash‑pull results with:
    • digital communications about drugs,
    • surveillance of brief hand‑to‑hand exchanges,
    • vehicle‑use patterns, and
    • phone location data.
    This multi‑source corroboration makes suppression challenges significantly harder.
  • Residential sales need not be observed: Officers do not have to catch the suspect selling drugs from the residence itself. Observed travel from the residence to suspected transactions and back, combined with drug‑related trash and communications, will often suffice.
  • Training and experience should be documented: Affidavits should explicitly link observed behaviors (short meetings, rotating vehicles, third‑party car ownership) to typical drug‑trafficking patterns, while also making sure those behaviors are concretely described.

B. For defense counsel: framing suppression challenges

For defense attorneys, Hawkins underscores:

  • The uphill battle in challenging warrants where an officer personally observes a suspect discarding trash with drug residue.
  • The need to attack not just a single fact (e.g., the trash pull) but the entire mosaic of the affidavit, since courts implement a holistic approach.
  • The limited utility of arguing that no sales occurred at the residence if:
    • the home plainly functions as a base of operations,
    • there is evidence of storage (e.g., residue, paraphernalia), and
    • the suspect travels directly between the residence and suspected drug transactions.
  • The importance of probing:
    • whether officers really observed the defendant discarding the trash,
    • how quickly the trash was recovered,
    • whether other people had access to that trash receptacle, and
    • whether there truly is corroborating evidence of ongoing trafficking.

C. For Sixth Circuit Fourth Amendment doctrine

Hawkins, though unpublished, is doctrinally important because it:

  • Applies the en banc framework in Sanders in a concrete, day‑to‑day context, emphasizing:
    • the low threshold for probable cause,
    • the appropriateness of relying on circumstantial evidence, and
    • the holistic evaluation of affidavits.
  • Solidifies the post‑Abernathy line that trash‑pull evidence can strongly support a home search when:
    • the trash is clearly traceable to the suspect and residence, and
    • there is corroborating evidence of drug activity.
  • Reinforces Higgins’s “fair shot” formulation and rejects a demand for direct evidence of drugs inside the home or for controlled buys there.
  • Signals that digital evidence (social media messages, phone pings) is now a routine and weighty component of probable‑cause showings in narcotics cases.

Although “not recommended for publication” and thus non‑precedential, Hawkins will likely be cited by prosecutors and district courts as persuasive authority in close suppression disputes involving trash pulls, digital evidence, and vehicle‑use patterns.

VII. Simplifying Key Legal Concepts

Several important Fourth Amendment concepts appear in the opinion. In plainer terms:

  • Probable cause
    This is a practical, common‑sense standard. It does not require proof “beyond a reasonable doubt” or even “more likely than not.” Instead, officers must show there is a fair probability—a decent chance—that evidence of a crime will be found in the place to be searched.
  • Nexus
    This is the required connection between:
    • the location officers want to search (here, Hawkins’s apartment), and
    • the items they hope to find (drugs, money, guns, records).
    It can be shown with direct evidence (e.g., an informant saw drugs in the apartment) or circumstantial evidence (e.g., the suspect leaves his home, meets someone briefly in a parking lot, returns home, and the trash from his home contains drug residue).
  • “Four corners” of the affidavit
    When a court decides whether a warrant had probable cause, it may look only at information within the written affidavit submitted to the judge. Officers and prosecutors cannot fix a weak affidavit later by adding facts that were not originally presented.
  • Trash pull
    A “trash pull” is when officers lawfully collect garbage that a resident has put out for collection or deposited in a publicly accessible dumpster. Courts generally treat such trash as abandoned property, meaning people have no reasonable expectation of privacy in its contents. Drug residue, packaging, or paraphernalia found there often supports probable cause to search the home—especially if officers saw the resident discard the trash.
  • Officer training and experience
    Courts allow officers to explain why certain behaviors are suspicious in light of their experience (for example, short meetings in parking lots, rotating vehicles, or third‑party vehicle registrations). This helps judges understand how the facts fit common drug‑trafficking patterns. But training and experience cannot replace actual facts; there must be some objective basis for suspicion.
  • Good‑faith exception
    Even if a warrant later turns out to lack probable cause, evidence may still be admitted if officers reasonably relied in good faith on the warrant issued by a neutral judge. Because the Sixth Circuit found that Hawkins’s warrant did have probable cause, it did not need to decide whether this exception would have saved the evidence anyway.

VIII. Conclusion

United States v. Hawkins is a comprehensive affirmation of how the Sixth Circuit now approaches probable cause to search a residence for drugs:

  • A single, well‑executed, observed trash pull showing drug residue—when officers have just watched the suspect bring the trash out of the home—can be a powerful anchor for a finding of probable cause.
  • When that physical evidence is reinforced by digital communications about drugs, phone location data, vehicle records and patterns, and observed short‑duration meetings characteristic of drug transactions, the “nexus” between home and contraband becomes robust.
  • The court explicitly rejects any rule requiring direct observation of sales from the residence or “ironclad evidence” that drugs are in the home; a “fair shot of finding contraband” suffices.
  • Officer “training and experience” is a legitimate interpretive tool, provided it is built on concrete observed facts and not used as a substitute for actual evidence.

In the broader Fourth Amendment landscape, Hawkins exemplifies the Sixth Circuit’s post‑Sanders commitment to a practical, totality‑driven, and relatively forgiving standard for probable cause. For law enforcement, it provides a roadmap for building resilient narcotics affidavits. For defense counsel, it illustrates the need to challenge not isolated facts but the coherence and strength of the entire evidentiary picture tying a residence to drug trafficking.

Case Details

Year: 2025
Court: Court of Appeals for the Sixth Circuit

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