“A Modicum Is Enough” – United States v. Hollins and the Sixth Circuit’s Refined Good-Faith & Drug-Premises Doctrine

1. Introduction

United States v. Kendall Hollins, No. 24-1465 (6th Cir. July 9, 2025), is the most recent articulation by the Sixth Circuit of two inter-related Fourth Amendment and sentencing doctrines:

How little evidence is necessary to trigger the Leon (United States v. Leon, 468 U.S. 897 (1984)) “good-faith” exception when officers obtain a single warrant covering multiple locations, some of which may lack probable cause; and
When a rented stash space such as a storage unit qualifies for the Sentencing Guidelines’ “drug-premises” enhancement, U.S.S.G. § 2D1.1(b)(12).

Appellant Kendall Hollins, a repeat narcotics offender in Benton Harbor, Michigan, sought to suppress drugs, firearms, and digital scales seized from his residence and two storage units, then argued that the district court erred in applying the drug-premises enhancement. The panel (Judges Boggs, McKeague, and Mathis) affirmed on both fronts, supplying nuanced guidance for future investigators, prosecutors, and sentencing courts.

2. Summary of the Judgment

The Sixth Circuit held:

The district court correctly denied Hollins’s motion to suppress. Even assuming the search-warrant affidavits lacked probable cause for Hollins’s residence and one storage unit, they were not “bare-bones.” Therefore, officers could (and did) reasonably rely on the issuing judge’s determination, bringing the evidence within the Leon good-faith exception.
The sentencing court properly imposed the two-level “drug-premises” enhancement because Hollins used storage unit 456 as a principal site to store distribution-quantity narcotics, notwithstanding his claim that it also contained personal belongings.
Accordingly, Hollins’s 108-month sentence was procedurally reasonable, and the conviction and sentence were affirmed.

3. Detailed Analysis

3.1 Precedents Cited and Their Influence

United States v. Sanders, 106 F.4th 455 (6th Cir. 2024) (en banc) – Provided the linchpin phrase adopted by the panel: a modicum of evidence, however slight connecting criminal activity to the place searched suffices to escape “bare-bones” status and trigger Leon good-faith. Hollins extends Sanders to multi-location warrants.
Leon and Herring v. United States, 555 U.S. 135 (2009) – Reiterated that suppression is reserved for deliberate, reckless, or grossly negligent police misconduct.
United States v. White, 874 F.3d 490 (6th Cir. 2017) – Defined “bare-bones” affidavits; Hollins employs that definition but stresses that overlap across locations does not automatically strip good-faith from the entire warrant.
United States v. Tripplet, 112 F.4th 428 (6th Cir. 2024) & United States v. Taylor, 85 F.4th 386 (6th Cir. 2023) – Clarified § 2D1.1(b)(12); Hollins follows their flexible approach, holding that storage alone can satisfy the “purpose” element.

3.2 The Court’s Legal Reasoning

Mixed standard of review. Legal conclusions de novo; factual findings for clear error.
Affidavit evaluation as a whole. Citing Whiteside, the panel refused “line-by-line” parsing, instead using “common sense.”
Minimally sufficient nexus. Key factors supporting good-faith for both the house and units included:
- Controlled buys proximate in time to trips to the house;
- Short, repeated entries into units 455 & 456 (characteristic of stash sites);
- Dog sniffs alerting twice (2021 & 2023);
- Informants’ fresh tips describing ongoing trafficking;
- Prior convictions and the officer’s training & experience.
Staleness rebutted. Earlier 2021 facts were rejuvenated by March 2023 buys, sniffs, and informant corroboration; firearms sought (durable items) further mitigated staleness.
Scope of Leon good-faith. Because neither affidavit was “entirely devoid” of indicia of probable cause, reliance remained objectively reasonable—even for the one location (unit 455) ultimately deemed lacking probable cause.
Drug-premises enhancement. The court emphasized three evidentiary pillars: (a) quantity of drugs found, (b) frequency/duration of unit 456 entries, and (c) Hollins’s stipulation of exclusive control and intended resale. It rejected the argument that dual-use (personal storage + drug stash) negates the enhancement.

3.3 Anticipated Impact

United States v. Hollins will likely influence:

Search-warrant drafting: Investigators can feel confident that minimal—yet articulable—links tying criminal activity to each location will protect evidence via Leon, even in multi-premise warrants.
Suppression litigation: Defendants will face a steeper climb; the “modicum” standard now expressly covers storage units and similar ancillary locations.
Sentencing practice: Prosecutors may invoke the drug-premises enhancement more frequently for “stash” facilities such as lockers, trailers, or detached garages, while defense counsel must marshal concrete evidence that the drug use was merely incidental.
Staleness doctrine: Hollins teaches that old facts can survive if (1) the alleged trafficking is continuous, or (2) the warrant covers durable contraband (guns, ledgers, paraphernalia).

4. Complex Concepts Simplified

Probable Cause vs. Good-Faith Reliance – Probable cause asks whether the affidavit would convince a reasonable judge that evidence exists at a place. Good-faith asks a different question: did officers act reasonably in relying on the judge’s warrant, even if the judge was wrong?
Bare-Bones Affidavit – One so deficient that any officer should know it cannot support a warrant (e.g., mere hunches, uncorroborated rumor). Not the same as a “weak” affidavit.
Leon Exception – A rule allowing evidence if police reasonably relied on a warrant. Suppression remains only to deter blatant or reckless misconduct.
Drug-Premises Enhancement – A two-level increase in the federal Sentencing Guidelines when the defendant maintains a place (house, unit, shed) for drug manufacture, storage, or distribution. “Maintain” means some degree of control; “purpose” includes storage for later sales, not just on-site dealing.
Staleness – Information is stale if too old to suggest current evidence. Continuous crimes (ongoing drug trafficking) and durable evidence (guns, records) lengthen the staleness window.

5. Conclusion

United States v. Hollins reinforces an increasingly permissive view of Leon good-faith within the Sixth Circuit: where an affidavit offers even “a modicum” of credible facts linking contraband to the place searched, suppression will rarely follow. Simultaneously, it broadens the reach of § 2D1.1(b)(12) by confirming that a rented storage unit used as a stash spot qualifies as a drug premises, regardless of legitimate dual use. Going forward, practitioners should draft warrants with at least one tangible nexus fact per location, anticipate staleness challenges with fresh corroboration, and recognize that even seemingly innocuous storage facilities may trigger sentencing enhancements if linked to drug commerce.