Introduction

In United States v. Bradley, No. 24-3906 (6th Cir. Oct. 20, 2025) (not recommended for publication), the Sixth Circuit affirmed the denial of a motion to suppress evidence seized from a Canton, Ohio residence and rejected the defendant’s efforts to reopen the suppression proceedings after trial. Writing for a panel that included Judges Larsen and Bloomekatz, Judge Kethledge applied the Sixth Circuit’s recent en banc decision in United States v. Sanders, 106 F.4th 455 (6th Cir. 2024), to hold that probable cause supported a residential search where the defendant was engaged in continuous, large-scale drug trafficking and investigators had additional, concrete ties between the trafficking activity and the home.

The appeal raised two principal issues: (1) whether the warrant affidavit established a sufficient nexus between drug trafficking and the residence on Nicholas Place to support probable cause, and (2) whether the district court abused its discretion by refusing to reopen the suppression hearing based on later-produced cellphone extraction data. The Sixth Circuit answered both in the government’s favor.

Summary of the Opinion

The court affirmed the district court’s denial of the suppression motion, holding that the warrant was supported by probable cause. Relying on Sanders and related precedents, the panel emphasized that while a suspect’s status as a drug dealer is not, standing alone, sufficient to search a home, the combination of ongoing, large-quantity trafficking and specific links to the residence permits a commonsense inference that evidence will be found there.

The panel also upheld the district court’s refusal to reopen suppression proceedings. Citing United States v. Pittman, 816 F.3d 419 (6th Cir. 2016), it reiterated that courts are “extremely reluctant” to reopen suppression hearings, particularly where the proffered basis is untimely and immaterial. The defendant’s reliance on an extracted dataset from one of multiple phones—received by defense counsel long before the motion and lacking dispositive value—did not justify reopening.

Key Facts Driving the Decision

• January 2020: Police intercepted a package containing one pound of methamphetamine addressed to “Cindy Williams” at the Nicholas Place address; a controlled delivery was made, and Patrick Bradley emerged from the house and put the package in a trash can.
• Multiple informants later reported Bradley was selling methamphetamine and cocaine; agents corroborated through controlled buys.
• November 2020: Bradley sold two ounces of cocaine to a police informant and met multiple times for installment payments. On one occasion, he left the Nicholas Place residence to meet the informant; on another, he returned to the same house after a payment. The vehicle he drove was registered to the Nicholas Place address.
• Two months later: Bradley again sold methamphetamine to the informant. He and the informant discussed the sale by call and text, with one call made from inside the Nicholas Place home. Bradley offered a pound of meth, the informant asked for an ounce. Bradley left the home, made stops, conducted the sale, and returned to the residence.
• Search warrant executed shortly after midnight: Police seized significant quantities of methamphetamine, cocaine, and MDMA, as well as a mixture of MDMA and cocaine.
• Post-indictment: The government produced extraction data for one Bradley phone. After conviction, Bradley twice moved to reopen suppression based on that data; the district court denied both motions.

Analysis

Precedents Cited and Their Influence

• United States v. Sanders, 106 F.4th 455 (6th Cir. 2024) (en banc). The court applied Sanders’s core teaching: a known dealer’s status alone is insufficient, but when the suspect is “engaged in continual and ongoing operations typically involving large amounts of drugs,” a judge may reasonably infer that the dealer uses his home to store drugs or otherwise further the operation. Bradley’s ongoing trafficking and large-quantity dealings—combined with home-linked facts—squarely fit that framework.
• United States v. Sheckles, 996 F.3d 330 (6th Cir. 2021). Sheckles explains that “fair probability” governs probable cause and that additional facts “fortify” the inference tying drug trafficking to a residence. In Bradley, those fortifying facts included phone calls from inside the home arranging a sale and repeated returns to the residence after drug transactions.
• United States v. Reed, 993 F.3d 441 (6th Cir. 2021). Reed cautions that a suspect’s “status alone” as a drug dealer cannot justify a residential search. The Bradley opinion explicitly acknowledges Reed and demonstrates compliance by marshalling multiple residence-specific facts beyond status.
• United States v. Williams, 544 F.3d 683, 687 (6th Cir. 2008). Williams recognizes the common-sense inference that traffickers use their homes to store drugs and further operations. Bradley invokes that principle, crystallized and refined through Sheckles and Sanders.
• United States v. Jones, 817 F.3d 489, 491 (6th Cir. 2016). Jones supports treating a vehicle registration listing a searched address as evidence of a “substantial connection” to that residence. The panel cited this to reject the notion that Bradley was merely a house guest.
• United States v. Brown, 732 F.3d 569, 573 (6th Cir. 2013). Brown underscores the deferential standard owed to the issuing judge’s probable cause determination. That deference bolstered the affirmance here.
• United States v. Russell, 26 F.4th 371, 374 (6th Cir. 2022). Russell sets out the appellate standards of review: clear error for factual findings and de novo for legal conclusions, with evidence viewed favorably to the prevailing party. The panel faithfully applied those standards.
• United States v. Rohrig, 98 F.3d 1506, 1524 (6th Cir. 1996). Rohrig’s admonition that the Fourth Amendment requires officers to act “reasonably, not flawlessly” answers Bradley’s argument that officers should have divined his claimed non-residency.
• United States v. Pittman, 816 F.3d 419, 424 (6th Cir. 2016). Pittman articulates the “extremely reluctant” standard governing motions to reopen suppression hearings. Bradley’s untimely and immaterial post-trial motion fell far short.

Legal Reasoning

The court’s analysis followed a structured path:

• Standard of review and deference. The panel reviewed the district court’s factual findings for clear error, legal conclusions de novo, and viewed the record favorably to the government’s position (Russell). It also afforded “great deference” to the issuing state judge’s probable cause determination (Brown).
• The nexus requirement and the “ongoing operations” inference. The panel recited the Sixth Circuit’s settled rules: “status alone” is insufficient (Reed), but ongoing, large-scale trafficking permits a reasonable inference that evidence will be found in the dealer’s home (Sanders; Williams). Bradley’s activities—multiple corroborated informant tips, controlled buys, offers to sell a pound of methamphetamine, and reference to a “half a brick” of cocaine—qualified as continuous, large-quantity operations.
• Additional residence-specific facts fortified the inference. The affidavit connected the operations to the Nicholas Place home:
  • Bradley made a call from inside the home to arrange a drug sale and to signal in code that a meth shipment had arrived, a textbook “fortifying” fact (Sheckles).
  • Officers repeatedly observed Bradley leaving from and returning to the home around drug transactions, including immediately after accepting payment.
  • Bradley’s vehicle was registered to the address, evidencing a substantial connection (Jones).
  • During a controlled delivery to that address, Bradley emerged from the house, retrieved the package, and disposed of it—behavior inconsistent with a mere guest.
  • Officers saw Bradley come and go from the house, including late at night, in the weeks preceding the search.
  Taken together, these facts created a fair probability that contraband, proceeds, or paraphernalia would be found in the residence that night.
• The “I didn’t live there” contention did not defeat probable cause. The court underscored that nothing in the record would have indicated to officers that Bradley was only an overnight guest post-breakup; the Fourth Amendment demands reasonableness, not perfection (Rohrig). In other words, the objective indicators known to police pointed to a substantial connection to the home.
• Reopening the suppression hearing. The court applied Pittman’s “extremely reluctant” standard and found Bradley’s post-trial motion untimely and meritless. Defense counsel had the extraction data nearly a year before the motion; a jury trial had intervened. Substantively, the fact that two calls referenced in the affidavit were not visible in one phone’s extracted dataset did not show those calls “did not happen,” especially since Bradley had multiple phones whose data could not be extracted. Defense counsel candidly acknowledged that this would not alter the suppression outcome. The panel also noted that new, fact-bound arguments not presented below did not establish an abuse of discretion.

Impact and Practical Implications

Bradley reinforces several important currents in Sixth Circuit Fourth Amendment law:

• Post-Sanders clarity on residential nexus. When investigators can demonstrate ongoing, large-quantity trafficking and offer concrete, even modest, links tying that activity to a residence (calls from inside, post-transaction returns, vehicle registration, behavior during controlled deliveries), the nexus requirement is satisfied. Bradley is a practical blueprint for drafting affidavits that will survive suppression challenges.
• Limits of the “status alone” doctrine. Reed’s constraint remains real; mere proof that a person is a drug dealer does not authorize a home search. But Bradley shows how little additional residence-specific evidence is needed when the trafficking is continuous and substantial in scale.
• Reasonableness over perfection in assessing residency. Absent contrary indicators known to police, objective ties like vehicle registration, observed comings and goings, and behavior at the property permit officers to treat a suspect as having a substantial connection to the home. Post hoc claims of non-residency will rarely defeat probable cause on appellate review.
• Post-trial motions to reopen suppression are uphill. Courts remain “extremely reluctant” to reopen; movants must show timely, genuinely new, and material grounds likely to alter the result. Data gaps in one of several devices—especially when known earlier—will not suffice.
• Unpublished but persuasive. Although “not recommended for publication,” Bradley can be cited under Fed. R. App. P. 32.1 and will likely be persuasive authority within the circuit for the proposition that the Sanders nexus inference is readily satisfied by targeted, corroborated links to a residence.

Complex Concepts Simplified

• Probable cause: A practical, nontechnical standard asking whether there is a “fair probability” that evidence of a crime will be found in the place to be searched. It is less than a preponderance and far less than proof beyond a reasonable doubt.
• Nexus requirement: In search-warrant law, there must be a link (nexus) between the place to be searched and the evidence sought. For residential searches involving drug trafficking, the Sixth Circuit permits an inference of nexus when the trafficking is ongoing and substantial, especially if augmented by residence-specific facts.
• Controlled delivery: A law enforcement technique where officers allow a suspicious parcel to be delivered under surveillance to observe who retrieves it and how it is handled, thereby generating evidence and often probable cause for further action.
• “Status alone” rule: A person’s status as a drug dealer, without more, is insufficient to justify a search of their residence (Reed). There must be additional facts linking the home to the criminal activity.
• Standards of review:
  • Clear error (facts): The appellate court defers to the district judge’s findings unless left with a firm conviction that a mistake has been made.
  • De novo (law): The appellate court decides legal issues anew, without deference.
  • Deference to issuing judge: Reviewing courts give “great deference” to the judge who issued the warrant’s probable cause determination.
• “Extremely reluctant” to reopen suppression: After a suppression ruling—especially after trial—courts rarely reopen absent a compelling, timely, and materially outcome-changing reason. Discoveries that were available earlier or that would not change the result are inadequate (Pittman).
• “Cleaned up” parenthetical: A citation convention indicating that internal quotation marks, alterations, and citations have been omitted to enhance readability without altering the substance of the quotation.

Application of the Rule to the Facts

Applying the “ongoing-operations-plus-nexus” framework, Bradley presents a near-canonical set of facts satisfying probable cause to search a residence:

• Ongoing, large-quantity trafficking: corroborated informant reports; multiple sales; discussions of a one-pound meth sale; reference to “half a brick” of cocaine.
• Residence-specific ties: a call from inside the home to arrange a sale and discuss shipment; repeated returns to the house after drug deals; vehicle registration at the address; controlled delivery behavior evidencing dominion; late-night comings and goings observed by police.
• Temporal proximity: The phone call from inside the home and the subsequent sale occurred the same evening the warrant issued and the search was executed, minimizing any staleness concern.

In this matrix, the issuing judge could reasonably find a fair probability that drugs, proceeds, and trafficking paraphernalia would be found at the residence that night.

Practice Notes

• For law enforcement and prosecutors: To solidify residential nexus, include concrete, recent indicators of drug activity tied to the home—calls made from inside, observed departures/returns bracketing deals, controlled-delivery interactions, registration records, and late-night presence. These modest facts can decisively “fortify” the Sanders inference.
• For defense counsel: To challenge nexus post-Sanders, identify and document affirmative disconnects (e.g., exclusive use of off-site stash houses, lack of access to the residence, contrary occupancy records, or strong temporal gaps) and raise them early. Post-trial efforts to revisit suppression require truly new, material information that was previously unavailable.
• On digital evidence: Absence of specific calls in a single device’s extraction does not necessarily negate their occurrence—especially where multiple devices are in play or extraction is incomplete. Materiality requires more than a data gap.

Conclusion

United States v. Bradley reinforces the Sixth Circuit’s post-Sanders approach to residential search warrants in drug trafficking cases: when the government can show ongoing, large-scale dealing and provide concrete, commonsense ties between the activity and the home, the nexus requirement is satisfied. The panel also underscores that courts will be exceedingly reluctant to reopen suppression proceedings on untimely and immaterial grounds—particularly after a jury conviction.

Although unpublished and nonbinding, Bradley is a clear, persuasive application of the “ongoing-operations-plus-nexus” rule and a practical guide for how modest residence-linked facts, layered atop corroborated trafficking evidence, will sustain probable cause in the Sixth Circuit.