United States v. Leonard: The Fifth Circuit Applies Massi’s “Close Enough to the Line of Validity” Good-Faith Doctrine to Defeat Suppression Where a Warrant Followed an Allegedly Unlawful Exigent Entry

1. Introduction

In United States v. Leonard (5th Cir. Feb. 11, 2026), the United States appealed a suppression order entered by the Eastern District of Texas. Police responding to a distress call found Xavier Jerel Leonard half-naked, bruised, and thrashing in a residential area, appearing intoxicated (possibly PCP). Officers traced Leonard to a nearby home, discovered an open door, saw signs of disarray (including a broken coffee table), entered briefly, and observed evidence of drugs and a firearm. An officer then applied for and obtained a search warrant, leading to the seizure of drugs, cash, and guns and federal charges under 18 U.S.C. § 922(g)(1) and 18 U.S.C. § 924(c).

The decisive appellate posture mattered: the Government did not contest the underlying Fourth Amendment merits on appeal. Instead, it argued that—assuming a constitutional violation—the exclusionary rule still should not apply because officers acted in good faith. The Fifth Circuit reversed suppression, holding the case fell within the circuit’s “close enough” good-faith doctrine derived from United States v. Massi, 761 F.3d 512 (5th Cir. 2014).

2. Summary of the Opinion

The panel (per curiam) reiterated that the exclusionary rule is a “disfavored judge-made remedy” used only as a “last resort” under Hudson v. Michigan, 547 U.S. 586, 591 (2006). It then applied the good faith exception as recognized in United States v. Leon, 468 U.S. 897 (1984) and, more specifically, the Fifth Circuit’s “close enough” variant from United States v. Massi.

On the facts—an incapacitated, injured resident found nearby; uncertainty about assault versus medical crisis; an open door; visible signs of a possible struggle; knock-and-announce followed by silence—the court held the officers’ initial entry was at least “close enough to the line of validity” that an objectively reasonable officer could believe the observations used in the warrant affidavit were not unconstitutionally tainted. Therefore, even if the entry were unlawful, suppression was unwarranted.

The Fifth Circuit REVERSED the suppression order and REMANDED.

3. Analysis

A. Precedents Cited

1) The exclusionary rule as a constrained, last-resort remedy

  • Hudson v. Michigan, 547 U.S. 586, 591 (2006): The majority used Hudson for the controlling theme that suppression is exceptional. This framing supports resolving close cases through limiting doctrines (attenuation, good faith) rather than exclusion.
  • Davis v. United States, 564 U.S. 229, 236-238 (2011) (concurrence): Invoked to emphasize that the Fourth Amendment “says nothing about suppressing evidence,” reinforcing that suppression is a judicially engineered tool, not a textual command.
  • Utah v. Strieff, 579 U.S. 232 (2016) (concurrence): Cited for modern narrowing of suppression through attenuation and for the view that deterrence benefits must outweigh heavy costs.
  • Herring v. United States, 555 U.S. 135, 143 (2009); Arizona v. Evans, 514 U.S. 1, 14-15 (1995) (concurrence): Used to stress that suppression is principally aimed at deterring intentional or “patently unconstitutional” conduct, not every error.
  • Egbert v. Boule, 596 U.S. 482, 491 (2022) (concurrence): Cited for the modern Court’s skepticism toward judge-made remedial innovation, used rhetorically to characterize the exclusionary rule as an artifact of an earlier era.

2) The good faith exception and the Fifth Circuit’s “close enough” doctrine

  • United States v. Leon, 468 U.S. 897, 908, 922 (1984): The foundation for admitting evidence seized pursuant to a warrant where officers acted with “objective reasonableness.” Here, it anchors the analysis away from pure Fourth Amendment violation and toward remedy/causation/deterrence.
  • United States v. Massi, 761 F.3d 512 (5th Cir. 2014): The controlling Fifth Circuit precedent. Massi permits admission where the officer’s conduct that generated information used in the warrant affidavit was “‘close enough to the line of validity’ that an objectively reasonable officer … would believe” the information was not unconstitutionally tainted. The Leonard majority treated the “close enough” standard as decisive and plainly satisfied by the emergency-like facts.
  • United States v. Holley, 831 F.3d 322 (5th Cir. 2016) (concurrence): Cited to illustrate intra-circuit disagreement and uncertainty in applying Massi—supporting the concurrence’s call for a clearer test.

3) Exigency / emergency-aid context informing “objective reasonableness”

  • Michigan v. Fisher, 558 U.S. 45, 49 (2009): The majority cited Fisher for the proposition that warrantless entry may be justified where there is an objectively reasonable basis to believe medical assistance is needed or persons are in danger. Leonard’s facts (injury, altered state, possible violence, open door, signs of struggle) supply the type of uncertainty Fisher tolerates.
  • United States v. McClain, 444 F.3d 556, 563, 565-66 (6th Cir. 2005): Used not as binding authority but as persuasive support for the key move: even if an open/ajar door alone may not establish probable cause or exigency, officers may not be “objectively unreasonable” in suspecting an emergency or crime—an idea that dovetails with Massi’s forgiving, remedial lens.

4) The concurrence’s historical and conceptual scaffolding

Judge Oldham’s concurrence (joined by Judge Wilson) provides a wide-ranging account of the exclusionary rule’s development and modern retrenchment, citing numerous authorities to argue that suppression doctrine is (a) atextual, (b) historically contingent, and (c) now sharply limited.

  • Early history and rejection themes: Bishop Atterbury's Case, 16 How. St. Tr. 323, 640 (1723); United States v. The La Jeune Eugenie, 26 F. Cas. 832, 843-844 (C.C.D. Mass. 1822).
  • Exclusionary-rule arc: Boyd v. United States, 116 U.S. 616 (1886); Adams v. New York, 192 U.S. 585 (1904); Weeks v. United States, 232 U.S. 383 (1914); Silverthorne Lumber Co. v. United States, 251 U.S. 385, 392 (1920); Wolf v. Colorado, 338 U.S. 25 (1949); Mapp v. Ohio, 367 U.S. 643 (1961).
  • Modern expansions/limits: Illinois v. Krull, 480 U.S. 340 (1987); Nardone v. United States, 308 U.S. 338, 340 (1939); Collins v. Virginia, 584 U.S. 586, 603 (2018) (Thomas, J., concurring).
  • Qualified-immunity alignment proposal: Messerschmidt v. Millender, 565 U.S. 535, 546 n.1 (2012); Malley v. Briggs, 475 U.S. 335, 344 (1986); District of Columbia v. Wesby, 583 U.S. 48, 63 (2018); Mullenix v. Luna, 577 U.S. 7, 11 (2015); Taylor v. Riojas, 592 U.S. 7, 9 & n.2 (2020).
  • Additional cases referenced in a footnote as part of a “full story”: Gouled v. United States, 255 U.S. 298 (1921); Agnello v. United States, 269 U.S. 20 (1925).

B. Legal Reasoning

1) The court’s chosen question: remedy, not right

Leonard is a textbook example of a court selecting the narrowest dispositive issue. Because the Government declined to litigate the underlying Fourth Amendment question on appeal, the Fifth Circuit addressed only whether suppression was an available remedy. That choice makes the exclusionary rule’s limits—and especially good faith—the fulcrum.

2) Applying Massi: “close enough” objective reasonableness

The majority treated the officers’ pre-warrant entry as, at minimum, plausibly within recognized exigency/emergency-aid rationales: an incoherent, injured resident found nearby; uncertainty whether there had been violence; an open door; a visible broken table suggesting a struggle; and no response to knock-and-announce. Even if a court might later decide those facts did not actually satisfy an exigent-circumstances exception, the key under Massi is whether the officers were objectively reasonable in believing they were acting near the constitutional line.

The court emphasized it did not matter whether the officers’ purpose was to search for an attacker, locate other victims, or find medical information—each rationale could qualify as exigency under cases like Michigan v. Fisher. The opinion’s central move is remedial: where the circumstances are sufficiently urgent and ambiguous, officers’ judgment calls fall within the “close enough” buffer that preserves reliance on a subsequently issued warrant.

3) The concurrence’s critique: “close enough” is too indeterminate

Judge Oldham agreed on outcome but argued Massi is under-specified and functions as an “I know it when I see it” test, undermining predictability and deterrence logic. His proposed refinement would expressly tie Massi’s “objective reasonableness” to the qualified immunity “clearly established law” framework:

  • Defendants should have to show an objectively reasonable officer would have known the conduct was unlawful by pointing to sufficiently specific, factually similar precedent (per District of Columbia v. Wesby and Mullenix v. Luna).
  • Absent such precedent, suppression would be available only for an “obvious” violation in an egregious case (per Taylor v. Riojas).

Importantly, this is a proposal, not the majority’s holding. But it signals a live doctrinal pressure in the Fifth Circuit: whether to formalize Massi into a more rule-like, precedent-sensitive test.

C. Impact

1) Practical effect in the Fifth Circuit: broader remedial safe harbor in emergency-adjacent entries

Leonard strengthens the Government’s hand in cases where officers make a short, safety-driven home entry under uncertain circumstances and later obtain a warrant. Even where the initial entry is contestable, Leonard confirms that Massi can preserve the evidence if the officers’ decision was plausibly grounded in exigency/emergency-aid reasoning. The opinion thus encourages litigants to treat suppression as a remedial inquiry—focused on deterrence and reasonableness—rather than an automatic consequence of a Fourth Amendment violation.

2) Litigation incentives: shifting suppression battles to “objective reasonableness” framing

Leonard also shows the strategic value (for the Government) of conceding or bypassing merits to concentrate on remedy—especially in circuits that recognize robust good-faith doctrines. Defendants, correspondingly, will need to develop records and arguments not just about illegality, but about why officers’ conduct was not even “close enough”—i.e., why it should have been clear to reasonable officers that entry was unlawful.

3) Doctrinal trajectory: potential alignment with qualified immunity (or resistance to it)

The concurrence lays down a roadmap to import qualified-immunity “clearly established law” into suppression. If adopted in future cases, that approach would raise defendants’ burdens substantially and make exclusion rarer. Even without adoption, the concurrence may influence how panels describe and constrain Massi, nudging toward more precedent-specific reasoning.

4. Complex Concepts Simplified

  • Exclusionary rule: A judicially created rule that can keep illegally obtained evidence out of a criminal trial, primarily to deter police misconduct.
  • Good faith exception (United States v. Leon): Even if a search is later found unlawful, evidence may still be admitted if officers acted with “objective reasonableness,” such as relying on a warrant.
  • “Close enough to the line of validity” (United States v. Massi): A Fifth Circuit doctrine allowing evidence where officers’ arguably unlawful conduct was near the constitutional boundary such that a reasonable officer could think it lawful—preventing suppression even when the warrant affidavit drew on that conduct.
  • Exigent circumstances / emergency aid (Michigan v. Fisher): Situations where officers may enter without a warrant because there is an objectively reasonable basis to believe someone needs immediate help or is in danger.
  • Fruit of the poisonous tree (discussed via Utah v. Strieff in concurrence): Evidence derived from an illegal search may be “poisoned,” but multiple doctrines (attenuation, good faith) can “unpoison” it for trial.
  • Qualified immunity “clearly established law” (concurrence proposal): In civil suits, officers often avoid liability unless prior precedent made the unlawfulness of their conduct clear in a specific, factually similar context. The concurrence suggests using that same clarity requirement to decide whether suppression should occur under Massi.

5. Conclusion

United States v. Leonard is a remedy-centered decision: it assumes away (for appellate purposes) the Fourth Amendment merits and instead underscores how the Fifth Circuit’s Massi “close enough” doctrine can defeat suppression when officers obtain a valid warrant after an emergency-tinged, arguably unlawful entry. The majority’s holding reinforces the modern Supreme Court’s recurring message (via cases like Hudson v. Michigan and United States v. Leon) that exclusion is exceptional and deterrence-driven.

Judge Oldham’s concurrence, meanwhile, frames Leonard as part of a broader retrenchment story and urges a clearer, more rule-like version of Massi tied to the qualified immunity “clearly established law” methodology. Whether or not that proposal is adopted, Leonard’s immediate significance is practical and doctrinal: in the Fifth Circuit, where officers confront ambiguous signs of danger or medical emergency, a later-obtained warrant will often be insulated from suppression because the pre-warrant conduct can be characterized as at least “close enough” to constitutional validity.