USA v. Walker

UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF LOUISIANA
UNITED STATES OF AMERICA
VERSUS
LEARTAY WALKER
CRIMINAL ACTION
NO. 24-97-JWD-EWD
RULING AND ORDER
This matter comes before the Court on the Motion to Suppress Evidence Seized Pursuant
to Search of Baystone Avenue (“Motion to Suppress”) (Doc. 32) filed by Defendant Leartay Walker
(“Defendant” or “Walker”). The Government opposes this motion. (Doc. 34.) The Court held a
hearing on January 14, 2026. (Doc. 38.) The Court has carefully considered the law, the facts in
the record, and the arguments and submissions of the parties and is prepared to rule. For the
following reasons, Defendant’s Motion to Suppress is denied.
I. BACKGROUND
On May 15, 2024, Trooper David Hernandez (“Hernandez”) of the Louisiana Department
of Public Safety applied for a warrant (“the Baystone Warrant”) to search 42490 Baystone Avenue,
Prairieville, Louisiana (“the Baystone Residence”). (Doc. 34 at 4; Doc. 37-1 at 1.) That same day,
Judge Jimmy Kuhn of the Twenty-Third Judicial District Court of Louisiana signed the search
warrant. (Doc. 34 at 4.) State troopers and deputies with the Narcotics Division of the East Baton
Rouge Sheriff’s Office (“EBRSO”) executed the search warrant on May 22, 2024. (Id.; Doc. 32-1
at 1.) The search yielded “approximately 9.8 pounds of powdered synthetic marijuana” and drug
paraphernalia, as well as three firearms, two of which were located in a safe to which Defendant
had the key. (Doc. 34 at 4–5.) On December 4, 2024, a grand jury indicted Defendant for one count
of possession of firearms by a convicted felon, in violation of 18 U.S.C. § 922(g)(1). (Doc. 1 at 1.)
Case 3:24-cr-00097-JWD-EWD Document 41 02/13/26 Page 1 of 13

2
Defendant was arrested on this federal charge on December 26, 2024. (Doc. 4 at 1.) He now moves
to suppress all evidence obtained during the search of the Baystone Residence on the ground that
the warrant application—specifically, Hernandez’s supporting affidavit—was deficient. (Doc. 32-
1 at 1, 3–4.)
II. BAYSTONE WARRANT
The Baystone Warrant—signed by Judge Kuhn—described the Baystone Residence and
authorized a search thereof for the purpose of seizing, inter alia, “[a]ny chemical compounds in
powder form,” “[s]olvents,” “[s]pray bottles/dispensers,” “[p]aper products that may have been
treated” (i.e., with synthetic marijuana), “[m]ail and/or addresses intended for . . . inmate[s],”
firearms, and U.S. currency. (Doc. 37-1 at 1–2, 7, 9–11.) In support of this warrant, Hernandez
swore the following: On May 10, 2024, Sergeant Eric David (“David”) of the EBRSO Narcotics
Division contacted Hernandez because David’s investigation of Defendant “ha[d] expanded [from
East Baton Rouge Parish] to Ascension Parish.” (Id. at 2.)
Subsequently, in support of the Baystone Warrant, David relayed to Hernandez that, on
March 13, 2024, investigators with the Nineteenth Judicial District Attorney’s Office informed the
EBRSO Narcotics Division that inmates at Catahoula Correctional Facility and East Baton Rouge
Parish Prison had been “buying and receiving illegal narcotics while incarcerated.” (Id. at 3.)
Specifically, investigators reported “numerous jail calls” where inmates discussed purchasing
“sheets.”1 (Id.) Investigators linked the sale of “sheets” to the Instagram account “TayySmilez.”
(Id.) David forwarded the account to Lieutenant Brandon Berggren (“Berggren”) of the EBRSO
Violent Crimes Unit. (Id.) Using various databases, Berggren identified Defendant as the owner
1 “Sheets” are “small pieces of dissolvable paper that are coated with synthetic marijuana” and which can be smoked
or dissolved orally. (Doc. 37-1 at 3.) “[C]hemical compounds used for synthetic marijuana are generally found in bulk
powder form” but can be “dissolved in solution” and “sprayed onto paper products” like mail in order to secret them
into jails and prisons for distribution and use. (Id.)
Case 3:24-cr-00097-JWD-EWD Document 41 02/13/26 Page 2 of 13

3
of the Instagram account and obtained Defendant’s most recent address (“the Cobblestone
Residence”)—located on Cobblestone Avenue in Geismar, Louisiana. (Id.) Berggren also obtained
Defendant’s cellphone number. (Id.)
Using East Baton Rouge Parish Prison’s inmate phone system, David confirmed
Defendant’s cellphone number. (Id. at 4.) He then “intercepted and transcribed” multiple calls
wherein Defendant discussed the sale of “sheets” with inmates, including on December 6, 2023;
February 28, 2024; March 1, 2024; March 15, 2024; April 12, 2024; April 19, 2024; and May 2,
2024. (Id. at 4–6.) On March 27, 2024, Judge William Jordan of the Nineteenth Judicial District
Court signed a “Pen Trap and Trace Search Warrant.” (Id. at 5.) Beginning April 4, 2024, David
“began receiving pings” for Defendant’s cellphone. (Id.) These pings had a radius of 3,300–5,000
meters and placed Defendant “within the area” of the Cobblestone Residence. (Id.) On April 5,
2024, EBRSO agents physically observed Defendant at the Cobblestone Residence. (Id.) Of the
four vehicles parked at the Cobblestone Residence—including in the garage—at least three were
registered to the residence and owned by Marlon and Toni Brady. (Id.)
During a jail call on April 12, 2024, Defendant explained that he stored drug proceeds in
two safes located “at his house [and] his mom’s house” and that he had a lot of money stashed in
each. (Id.) Then, on May 13, 2024, David learned that the Baton Rouge Police Department
(“BRPD”) had stopped Defendant and his girlfriend, Diamond Smith (“Smith”), while they were
driving. (Id. at 6.) “During the traffic stop, [Defendant] fled the scene on foot.” (Id.) “Smith was
booked into the East Baton Rouge Parish Prison for active Bench Warrants.” (Id.) From this
episode, David and Berggren learned that Smith resided at the Baystone Residence. (Id.) They then
checked the aforementioned jail calls against ping data and determined that Defendant was in the
radius of the Baystone Residence during “several jail calls in which [he] t[old] inmates that he was
Case 3:24-cr-00097-JWD-EWD Document 41 02/13/26 Page 3 of 13

4
at home or making . . . ‘sheets.’” (Id.) These included the calls on April 12 and April 19, 2024.
(Id.) Finally, on May 14, 2024, David physically surveilled the Baystone Residence, at which time
he observed Defendant’s vehicle “parked in the driveway in front of the residence.” (Id. at 7.)
Based on David’s “years of experience” and the facts recited, he believed that Defendant was
making “sheets” at the Baystone Residence, as well as “concealing or storing some of the illegal
proceeds . . . at a safe in his mother[’]s residence” (i.e., the Cobblestone Residence). (Id.)
III. PARTIES’ ARGUMENTS
A. Defendant’s Motion to Suppress (Doc. 32)
Defendant notes that Hernandez’s affidavit mostly relied on jail calls, cellphone pings
which had a radius of 3,300–5,000 meters, and “[o]ccasional” physical surveillance. (Doc. 32-1 at
1.) Defendant explains that an affidavit in support of a search warrant must “demonstrate a
connection between the alleged criminal activity and the residence to be searched.” (Id. at 2 (citing
United States v. Satterwhite, 980 F.2d 317, 321 (5th Cir. 1992)).) Here, he argues, the affidavit
“did not establish probable cause to believe [that] contraband would be found” at the Baystone
Residence, because (1) the jail calls did not mention the residence “or suggest that [it] contained
drugs or firearms,” and (2) the cellphone pings were imprecise. (Id. at 3.) Relatedly, Defendant
contends that Hernandez’s affidavit “was so conclusory that no reasonable officer could rely upon
it in good faith.” (Id. (citing United States v. Leon, 468 U.S. 897, 923 (1984); United States v.
Payne, 341 F.3d 393, 400 (5th Cir. 2003)).)
B. Government’s Opposition (Doc. 34)
The Government highlights the following: On May 13, 2024, David and Berggren “were
able to determine that Smith lived at” the Baystone Residence. (Doc. 34 at 4.) Subsequently, they
“match[ed] several jail calls in which Walker advised inmates that he was at home or making
Case 3:24-cr-00097-JWD-EWD Document 41 02/13/26 Page 4 of 13

5
‘sheets.’” (Id.) Cellphone pings revealed that, “[a]t the time of these phone calls,” Defendant was
“at or near” the Baystone Residence. (Id.) Then, on May 14, 2024, David and Berggren physically
surveilled the residence, at which time they “observed Walker’s vehicle parked in the driveway.”
(Id.) The Government therefore contends that (1) the good-faith exception applies and
(2) Hernandez’s affidavit “adequately articulated the requisite probable cause.” (Id. at 1.)
The Government explains that “[c]ourts confine their good-faith inquiry to ‘the objectively
ascertainable question whether a reasonably well trained officer would have known that the search
was illegal despite the [judge’s] authorization.’” (Id. at 6 (quoting Leon, 468 U.S. at 922 n.23).)
Based on his experience, Hernandez “had no reason to believe that the information that he
included” in his affidavit was deficient. (Id. at 6–7.) Further, the Government argues, law
enforcement took “reasonable, gradual steps” during the investigation, including reviewing jail
calls, tying the Instagram account to Defendant, using databases to identify Defendant’s address
and cellphone number, obtaining a “trap and trace” warrant, pinging Defendant’s cellphone, and
physically surveilling Defendant. (Id. at 7.) The Government argues that, given these steps,
Hernandez’s affidavit was also “adequately supported by probable cause.” (Id. at 8.)
C. Suppression Hearing
At the suppression hearing on January 14, 2026, the Government reiterated that
Hernandez’s affidavit “meticulous[ly]” established probable cause. (Hearing Jan. 14, 2026.) It also
emphasized that the burden is on Defendant. (Id.) Consequently, the Government did not put on
any witnesses, instead relying upon the “four corners” of Hernandez’s affidavit. (Id.) According
to the Government, the affidavit is not “bare bones,” and so the good-faith exception applies. (Id.)
Specifically, the Government pointed to Defendant’s relationship with Smith, the fact that Smith
was known to live at the Baystone Residence, the physical surveillance of Defendant at the
Case 3:24-cr-00097-JWD-EWD Document 41 02/13/26 Page 5 of 13

6
Baystone Residence on May 14, 2024, and the cellphone pings indicating that Defendant could
have been at the Baystone Residence during jail calls where he discussed making “sheets.” (Id.)
Defendant countered that nothing in Hernandez’s affidavit suggested a nexus between
Defendant’s allegedly selling “sheets” and the Baystone Residence. (See id. (“The affidavit never
answers the only question the Fourth Amendment requires: Why would evidence be inside Mr.
Walker’s home?”).) Instead, Defendant observed, the affidavit mentioned jail calls and ping data
with a radius of 3,300–5,000 meters. (Id.) Further, much of the affidavit focused on the
Cobblestone Residence, not the Baystone Residence. (Id.)
IV. LEGAL STANDARD
“The Fourth Amendment requires that search warrants be issued only ‘upon probable
cause, supported by Oath or affirmation, and particularly describing the place to be searched, and
the persons or things to be seized.’” Dalia v. United States, 441 U.S. 238, 255 (1979) (quoting
U.S. Const. amend. IV). This language is “precise and clear.” Id. (quoting Stanford v. Texas, 379
U.S. 476, 481 (1965)). It requires “three things”: (1) “[W]arrants must be issued by neutral,
disinterested [judges].” Id. (citing, inter alia, Connally v. Georgia, 429 U.S. 245, 250–51 (1977)
(per curiam)). (2) “[T]hose seeking the warrant must demonstrate to the [issuing judge] their
probable cause to believe that ‘the evidence sought will aid in a particular apprehension or
conviction’ for a particular offense.” Id. (quoting Warden v. Hayden, 387 U.S. 294, 307 (1967)).
And (3) “warrants must particularly describe the ‘things to be seized’” and the “place[s] to be
searched.” Id. (quoting Stanford, 379 U.S. at 485). “The proponent of a motion to suppress has the
burden of proving, by a preponderance of evidence, that the evidence . . . was obtained in violation
of his Fourth Amendment rights.” United States v. Smith, 978 F.2d 171, 176 (5th Cir. 1992).
Case 3:24-cr-00097-JWD-EWD Document 41 02/13/26 Page 6 of 13

7
V. DISCUSSION
A. Good-Faith Exception
1. Applicable Law
“Deference to the judge issuing the warrant and the exclusionary rule’s focus on deterring
police misconduct results in the good-faith exception to the suppression remedy . . . .” United
States v. Morton, 46 F.4th 331, 336 (5th Cir. 2022) (en banc) (citing Leon, 468 U.S. at 922). Per
the exception, the fruits of a search are admissible if “obtained by law enforcement officers acting
in objectively reasonable reliance on a search warrant issued by a detached and neutral [judge].”
United States v. Pigrum, 922 F.2d 249, 252 (5th Cir. 1991). The exception can apply even where
“the affidavit on which the warrant was based is insufficient to establish probable cause.” Id.
(citing, inter alia, Leon, 468 U.S. at 927–28 (Blackmun, J., concurring)).
In considering whether the good-faith exception applies, a court confines its inquiry “to the
objectively ascertainable question whether a reasonably well trained officer would have known
that the search was illegal despite the [judge’s] authorization.” Payne, 341 F.3d at 400 (quoting
Leon, 468 U.S. at 922 n.23). Typically, this determination hinges on examination of the affidavit.
Id. The Fifth Circuit has explained that there are four situations where officers’ reliance on a
warrant is unreasonable, such that the good-faith exception does not apply:
1) the magistrate issued [the warrant] based on information the affiant knew was
false or should have known was false but for reckless disregard of the truth; 2) the
magistrate wholly abandoned the judicial role; 3) the warrant is based on an
affidavit so lacking in probable cause as to render belief in its existence
unreasonable; and 4) the warrant is facially deficient in particularizing the place to
be searched or things to be seized.
Morton, 46 F.4th at 336 (citing Leon, 468 U.S. at 923; United States v. Triplett, 684 F.3d 500, 504
(5th Cir. 2012)).
Case 3:24-cr-00097-JWD-EWD Document 41 02/13/26 Page 7 of 13

8
2. Analysis
Here, Defendant “tries to defeat” the good-faith exception by invoking the third situation—
i.e., by arguing that Hernandez’s affidavit did not establish probable cause to search the Baystone
Residence. See Morton, 46 F.4th at 336; see also Messerschmidt v. Millender, 565 U.S. 535, 546–
47 (2012) (citing Leon, 468 U.S. at 921) (“Our precedents make clear . . . that the threshold for
establishing this exception [to the good-faith exception] is a high one, and it should be.”).
Defendant is correct, of course, that a warrant application must be “supported by more than a ‘bare
bones affidavit.’” Pigrum, 922 F.2d at 252 (citing United States v. Maggitt, 778 F.2d 1029, 1035
(1985)); accord United States v. Wilson, 153 F.4th 478, 484 (5th Cir. 2025). That is, “the affidavit
must provide ‘the [issuing judge] with facts, and not mere conclusions, from which he could
determine probable cause.’” United States v. Gallegos, 239 F. App’x 890, 894 (5th Cir. 2007)
(quoting Satterwhite, 980 F.2d at 321); see also Wilson, 153 F.4th at 484 (explaining that “[s]uch
‘bare-bones affidavits’ are rare” (quoting Satterwhite, 980 F.2d at 320)); Morton, 46 F.4th at 336–
37 (collecting examples of “bare bones” affidavits).
Likewise, Defendant is correct that, in order for the good-faith exception to apply, “[t]he
affidavit must establish a nexus between the [place] to be searched and the evidence sought.”
Gallegos, 239 F. App’x at 895 (quoting United States v. Freeman, 685 F.2d 942, 949 (5th Cir.
1982)); see also Wilson, 153 F.4th at 485–86 (explaining that courts have “deemed affidavits bare
bones when they [have] ‘provided no information linking the [criminal] investigation to [the
defendant’s] residence’” (quoting United States v. Brown, 567 F. App’x 272, 282 (5th Cir. 2014))).
Nexus “may be established . . . by direct observation or through normal inferences as to where the
articles sought would be located.” Gallegos, 239 F. App’x at 895–96 (citing, inter alia, Freeman,
685 F.2d at 949). “Under the good-faith exception, the question becomes ‘whether officers
Case 3:24-cr-00097-JWD-EWD Document 41 02/13/26 Page 8 of 13

9
objectively could reasonably believe that there was such a nexus.’” Wilson, 153 F.4th at 485
(quoting United States v. Norman, 129 F.4th 874, 876 (5th Cir. 2025) (quoting United States v.
Bell, 832 F. App’x 298, 301 (5th Cir. 2020) (per curiam))).
In United States v. Wilson, the Fifth Circuit determined that the good-faith exception did
not apply where the affidavit in support of the search warrant “offered nothing—no observations,
no inferences, no corroborated tips—linking” a green pistol involved in an aggravated assault at a
Waffle House to the residence searched. Id. at 485; see also id. at 488 (“Here, nothing suggests
that any crime—or evidence of one—ever touched [the residence].”). The court explained: “Even
if [the defendant] lived there—and the record makes that claim dubious, at best—that fact alone
cannot justify a search.” Id. at 485. “[T]he fact that there is probable cause to believe that a person
has committed a crime does not automatically give the police probable cause to search his house
for evidence of that crime.” Id. (quoting Freeman, 685 F.2d at 949).
Here, Hernandez’s affidavit is rather detailed. But limited facts recounted therein suggest
a nexus between Defendant’s alleged criminal conduct and the Baystone Residence. Having
carefully examined the affidavit, the Court identifies the following: First, after linking the
Instagram account “TayySmilez” to Defendant, David and Berggren used various databases to find
Defendant’s listed address—the Cobblestone Residence, located in Geismar—as well as
Defendant’s cellphone number. (Doc. 37-1 at 3.) David confirmed that Defendant had placed
multiple calls to inmates at East Baton Rouge Parish Prison. (Id. at 4.) During a jail call on April
12, 2024, Defendant explained that he stored drug proceeds in two safes located “at his house [and]
his mom’s house” and that he had a lot of money stashed in each. (Id. at 5.) While physically
surveilling Defendant at the Cobblestone Residence on April 5, 2024, EBRSO agents determined
that at least three of the vehicles parked at the residence—including in the garage—were registered
Case 3:24-cr-00097-JWD-EWD Document 41 02/13/26 Page 9 of 13

10
to the residence and belonged not to Defendant but to Marlon and Toni Brady. (Id.) David
subsequently described the Cobblestone Residence as Defendant’s mother’s residence. (Id. at 7.)
Based on the April 12 jail call, David was aware that Defendant resided at, and stored drug
proceeds at, a second location. (Id. at 5.)
Second, on May 13, 2024, David learned that BRPD had stopped Defendant and Smith
while they were driving and that Defendant had “fled the scene on foot.” (Id. at 6.) “Smith was
booked into the East Baton Rouge Parish Prison for active Bench Warrants.” (Id.) From this
episode, David and Berggren learned that Smith resided at the Baystone Residence. (Id.) They then
cross-referenced ping data with jail calls, which revealed that Defendant was within the radius of
the Baystone Residence at the same time as he was telling inmates that “he was at home or making
. . . ‘sheets.’” (Id.) These included calls on April 12 and April 19, 2024. (Id. at 5–6.) On May 14,
2024—the day after the traffic stop and Smith’s booking—David physically observed Defendant’s
vehicle “parked in the driveway in front of the [Baystone Residence].” (Id. at 7.) David stated that,
based on his “years of experience,” he believed that Defendant was manufacturing “sheets” at the
residence. (Id.) Aside from the Cobblestone and Baystone Residences, Hernandez’s affidavit does
not mention any locations where Defendant was surveilled or suspected to reside. (See id. at 2–7.)
Thus, unlike the affidavit in Wilson, Hernandez’s affidavit contained some facts indicating
that the Baystone Residence was one of the two addresses at which Defendant resided and at which
he stored drug proceeds. (Id. at 4, 6–7.) It also contained some facts indicating that Defendant
made “sheets” at the Baystone Residence. (Id. at 5–6.) These facts were coupled with David’s
statement that, based on his “years of experience,” he believed that Defendant was making “sheets”
at the residence. See also Bell, 832 F. App’x at 301–02. Even if it is a “close call” whether the
above establishes probable cause, the nexus-related facts contained in Hernandez’s affidavit are
Case 3:24-cr-00097-JWD-EWD Document 41 02/13/26 Page 10 of 13

11
not so thin that the affidavit can be classified as “bare bones.” See Morton, 46 F.4th at 336–38
(explaining that, while it was “a close call whether the evidence recounted in the affidavits
established probable cause,” the affidavits did “have some meat on the bones”); see also id. at 338
(“As [the Fifth Circuit] ha[s] emphasized, on close calls second guessing the issuing judge is not
a basis for excluding evidence.”); Pigrum, 922 F.2d at 252 (explaining that the good-faith
exception can apply even where “the affidavit on which the warrant was based is insufficient to
establish probable cause”).
This Court “do[es] not decide if the state judge should have authorized” the search of the
Baystone Residence in the first place. See Morton, 46 F.4th at 339; see also Leon, 468 U.S. at 921–
22. Rather, the Court decides only whether “the officers acted in good faith when relying on the
judge’s decision to issue” the Baystone Warrant. See Morton, 46 F.4th at 339. “Whatever one
might conclude in hindsight about the strength of the evidence it recounts, [Hernandez’s] affidavit
is not ‘wholly conclusory.’” See id. at 337 (quoting Satterwhite, 980 F.2d at 321). Nor was it
objectively unreasonable for officers to believe that there existed the requisite nexus. See Wilson,
153 F.4th at 485; see also United States v. Christian, 925 F.3d 305, 313 (6th Cir. 2019) (“An
affidavit need only present ‘some connection, regardless of how remote it may have been’ . . . .”
(quoting United States v. White, 874 F.3d 490, 497 (6th Cir. 2017))); Leon, 468 U.S. at 921 (“In
the ordinary case, an officer cannot be expected to question the [issuing judge’s] probable-cause
determination . . . .”). The Court is bound to apply the good-faith exception; suppression is
therefore inappropriate. See Bell, 832 F. App’x at 301.
B. Probable Cause
1. Applicable Law
Probable cause exists “where the facts and circumstances within the affiant’s knowledge,
Case 3:24-cr-00097-JWD-EWD Document 41 02/13/26 Page 11 of 13

12
and of which he has reasonably trustworthy information, are sufficient unto themselves to warrant
a man of reasonable caution to believe that an offense has been or is being committed.” Berger v.
New York, 388 U.S. 41, 55 (1967) (citations omitted). “Mere affirmance of belief or suspicion is
not enough.” Nathanson v. United States, 290 U.S. 41, 47 (1933).
However, “[b]ecause a search warrant provides the detached scrutiny of a neutral [judge],
which is a more reliable safeguard against improper searches than the hurried judgment of a law
enforcement officer engaged in the often competitive enterprise of ferreting out crime, . . . [the
Supreme Court has] expressed a strong preference for warrants and declared that in a doubtful or
marginal case a search under a warrant may be sustainable where without one it would fall.” Leon,
468 U.S. at 913–14 (cleaned up). “Reasonable minds frequently may differ on the question whether
a particular affidavit establishes probable cause, and [the Supreme Court] ha[s] thus concluded
that the preference for warrants is most appropriately effectuated by according ‘great deference’
to [the issuing judge’s] determination.” Id. at 914 (quoting Spinelli v. United States, 393 U.S. 410,
419 (1969)). Thus:
The task of the issuing magistrate is simply to make a practical, common-sense
decision whether, given all the circumstances set forth in the affidavit before him,
including the ‘veracity’ and ‘basis of knowledge’ of persons supplying hearsay
information, there is a fair probability that contraband or evidence of a crime will
be found in a particular place. And the duty of a reviewing court is simply to ensure
that the magistrate had a “substantial basis for . . . conclud[ing]” that probable
cause existed.
Illinois v. Gates, 462 U.S. 213, 238–39 (1983) (quoting Jones v. United States, 362 U.S. 257, 271
(1960)).
2. Analysis
The Fifth Circuit uses “a two-step test to determine whether to apply the exclusionary rule”:
(1) Does the good-faith exception apply? United States v. Mays, 466 F.3d 335, 342–43 (5th Cir.
Case 3:24-cr-00097-JWD-EWD Document 41 02/13/26 Page 12 of 13

13
JUDGE JOHN W. deGRAVELLES
UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF LOUISIANA
2006) (citing United States v. Laury, 985 F.2d 1293, 1311 (5th Cir. 1993)). (2) Was the warrant
supported by probable cause? Id. If the good-faith exception applies, then step two is gratuitous,
“unless the case presents a ‘novel question of law whose resolution is necessary to guide future
action by law enforcement officers and [issuing judges].’” Id. at 343 (quoting Laury, 985 F.2d at
1311). “Principles of judicial restraint and precedent dictate that, in most cases, [courts] should not
reach the probable cause issue if a decision on the admissibility of evidence under the good-faith
exception will resolve the matter.” Gallegos, 239 F. App’x at 893 (internal quotation marks
omitted) (quoting United States v. Flanders, 468 F.3d 269, 270 (5th Cir. 2006)).
Here, the Court has already determined that the good-faith exception applies. And
Defendant’s motion does not present a “novel question of law” requiring the Court to advance to
the second step of the Fifth Circuit’s two-step test. See Mays, 466 F.3d at 343 (quoting Laury, 985
F.2d at 1311); Satterwhite, 980 F.2d at 320. “Consequently, the Court will not venture beyond its
finding that the good-faith exception applies.” See United States v. Davis, No. 22-93, 2025 WL
3252566, at *10 (M.D. La. Nov. 21, 2025) (deGravelles, J.).
VI. CONCLUSION
Accordingly,
IT IS ORDERED that Defendant’s Motion to Suppress Evidence Seized Pursuant to
Search of Baystone Avenue (Doc. 32) is DENIED.
Signed in Baton Rouge, Louisiana, on February 13, 2026.
S
Case 3:24-cr-00097-JWD-EWD Document 41 02/13/26 Page 13 of 13