USA v. Webb

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IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF ILLINOIS
UNITED STATES OF AMERICA,
Plaintiff,
vs.
CHRISTOPHER L. WEBB,
Defendant.
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Case No. 25-cr-40019-SMY
MEMORANDUM AND ORDER
YANDLE, Chief Judge:
Defendant Christopher Webb is charged with possession with intent to distribute a
controlled substance in violation of 21 U.S.C. § 841(a)(1) and § 841(b)(1)(A)(viii) (Doc. 1). Now
pending before the Court is Defendant’s Motion to Suppress Evidence and Statements (Doc. 25).
The Government has responded in opposition to the motion (Doc. 28). For the following reasons,
the motion is 	DENIED.
Factual Background
Christopher Webb is charged with possession with intent to distribute a controlled
substance based on evidence obtained through a February 21, 2025, search of a camper Webb
allegedly used as a primary residence. The search was performed by local authorities pursuant to
a warrant issued by a state judge in the Third Judicial District of Illinois based on an affidavit
attached to the warrant application.
The following are the facts as presented in the affidavit and are undisputed (Doc. 28-1):
Coty Hampton was questioned by local authorities following a report of a residential burglary on
February 21, 2025. Hampton and two other individuals had been identified in surveillance footage,
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and 	a 	consent 	search 	of 	Hampton’s 	person 	and 	vehicle 	yielded 	a 	small 	amount 	of
methamphetamine and pieces of stolen property from the burglary. During an interview with the
local police department, Hampton provided a statement detailing the burglary. He explained that
after the burglary, he drove one of his accomplices to the camper where Christopher Webb is
alleged to have been residing, which is located on the property of another individual. According
to Hampton, his accomplice entered the camper and exchanged some of the stolen property for
methamphetamine, a portion of which was later given to Hampton as payment for providing
transportation. Hampton also claimed to have personally observed large amounts of narcotics and
cash inside the camper within the previous month.
Based on the information provided by Hampton, local authorities applied for a search
warrant which was issued later the same day. 	When executing the search warrant, the officers
found approximately 203.6 grams of methamphetamine. 	Webb was subsequently arrested and
agreed to a post-Miranda interview in which he gave inculpatory statements confirming his
participation in trafficking methamphetamine.
Legal Standard
Pursuant to the Fourth Amendment, no search warrant shall be issued unless supported by
probable cause. 	U.S. CONST. amend. IV. 	Probable cause exists when a supporting affidavit
“presents a total set of circumstances which create a ‘fair probability’ that a search will uncover
evidence of a crime.” 	United States v. Haynes, 882 F.3d 662, 665 (7th Cir. 2018) (citing 	Illinois
v. Gates, 462 U.S. 213, 238 (1983)). 	The probable cause determination of the issuing judge or
magistrate is afforded great deference. 	Id.
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Discussion
Webb moves to exclude evidence obtained from the search of the camper as well as his
statements made subsequent to arrest, arguing the information contained in the affidavit was
insufficient to establish probable cause. Specifically, Webb argues the information Coty Hampton
provided to local police lacked detail, there was no firsthand observation of the alleged drug
transaction, there was no corroboration, and the informant did not testify before the issuing judge.
The Government argues the information received from Hampton was reliable because his
statements included an admission of his personal participation in a crime. In the alternative the
Government argues a warrant was not necessary because the automobile exception applies to the
search of the camper and the good faith exception to the exclusionary rule also applies.
When the information in search warrant application is based primarily on a tip from an
informant, courts look to the following factors in assessing the informant’s credibility: (1) the level
of detail provided; (2) the extent of the informant's firsthand knowledge; (3) the degree of
corroboration by law enforcement; (4) the time between the reported events and the warrant
application; and (5) whether the informant testified before the issuing judge. 	United States v.
Johnson, 655 F.3d 594, 600 (7th Cir. 2011). No single factor is determinative. 	United States v.
Taylor, 471 F.3d 832, 840 (7th Cir. 2006).
Here, according to the affidavit, Hampton told officers the address of the camper, that
Webb used the camper as his residence, and that he personally had seen “large amounts of narcotics
and cash” inside the camper within the previous month (Doc. 28-1 at 1-2). However, as Defendant
points out, the affidavit does not include any information about the type or quantity of drugs
Hampton claims to have seen or their location within the camper, nor does it identify the stolen
items that were traded for drugs and thus would likely be found inside the camper—things
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Hampton presumedly would have known. 	By itself, this information falls short of the level of
detail the Seventh Circuit has found sufficient to support an informant’s reliability. 	See, e.g.,
United States v. Peck, 317 F.3d 754, 756 (7th Cir. 2003) (No probable cause where “[t]he only
details [the informant] gave were that she had been in the house and was shown drugs . . . . [she]
failed to give specific details about … where the drugs were hidden, the total amount of drugs
Peck possessed, or the frequency with which Peck sold drugs.”)
With respect to the extent of his firsthand knowledge, Hampton claimed to have driven his
accomplice to the camper where the drug transaction took place and to have received a share of
the methamphetamine as payment for providing transportation. While Hampton did not enter the
camper or directly witness the alleged transaction, the fact that he saw his accomplice exit the
camper with illegal narcotics and received a portion of said narcotics supports the conclusion that
more narcotics would be found within the camper. This is all the probable cause inquiry requires.
See United States v. Miles, 86 F.4th 734, 741 (7th Cir. 2023) (finding probable cause when an
accomplice “gave the [informant] meth immediately after exiting the residence and returning to a
vehicle,” even though the informant “did not enter the house during the controlled buys”).
The Government asserts Hampton’s statements about the burglary were corroborated by a
review of surveillance footage. 	While this may be true, Webb is not alleged to have participated
in the burglary. The corroboration of statements regarding a separate crime to which Webb was
not a party can only bolster Hampton’s general credibility—it does not serve as corroboration of
his statements regarding the alleged drug transaction between Webb and a third party. 	See Junkert
v. Massey, 610 F.3d 364, 368 (7th Cir. 2010) (“[W]hile this information might go to the
[informant]’s past reliability on other crimes not involving Junkert, it supplies no details to support
the [informant]’s generalized assertions that Junkert was engaged in criminal activity.”) (citing
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Peck, 317 F.3d at 757). 	The affidavit does not reflect corroboration of Hampton’s statements
regarding Webb’s alleged possession or sale of methamphetamine.
The alleged drug transaction, the police interview with Hampton, and the application for
and execution of the warrant all occurred on the same day. 	Although Hampton claimed he
observed “large amounts of narcotics and cash” inside the camper approximately a month before
his interview, this does not diminish his reliability given the recency of the information regarding
the drug exchange in the same camper. Finally, the Court concludes from the lack of evidence or
suggestion by the Government that Hampton testified before the issuing judge that no such
testimony was given.
An informant’s credibility is determined under the totality of the circumstances, and other
considerations can compensate for deficiencies under any one factor. 	Taylor, 471 F.3d at 840
(“[A] deficiency in one factor may be compensated for by … some other indication of reliability.”).
In this case, Hampton’s firsthand knowledge regarding the exchange of stolen property for
methamphetamine and the short time between the reported events and the warrant application
indicate his reliability as an informant. 	Moreover, although the affidavit contains no express
statements by law enforcement regarding Hampton’s reliability, such as previous history of
providing accurate information to law enforcement, the fact that he gave statements against penal
interest bolsters his credibility. 	Hampton not only confirmed his participation in a burglary but
also admitted to accepting a portion of the methamphetamine from the alleged exchange as
payment. 	See United States v. Olson, 408 F.3d 366, 371 (7th Cir. 2005) (“[I]nformants attempting
to strike a bargain with the police have a strong incentive to provide accurate and specific
information rather than false information about a defendant's illegal activity.”) (cleaned up).
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Even if the totality of the circumstances did not support a finding of probable cause, the
Court finds the good faith exception to the exclusionary rule would apply. Under that doctrine, an
officer’s good-faith reliance on the validity of a search warrant will be upheld unless the affiant
provided false information, the issuing judge wholly abandoned the judicial role, the affidavit was
“so lacking in indicia of probable cause as to render official belief in its existence entirely
unreasonable,” or the warrant was “so facially deficient in particularizing its scope that the officers
could not reasonably presume it was valid.” 	United States v. Leon, 468 U.S. 897, 923 (1984).
As previously noted, the affidavit in question included information from an informant with
firsthand knowledge that a drug exchange had occurred at a specified address within the past
twenty-four hours, and the tip was bolstered by statements against penal interest. 	While the
affidavit was relatively light on detail and corroboration, it was not so totally lacking in indicia of
probable cause that a reasonable law enforcement officer would not think the resulting warrant
valid. 	See United States v. Koerth, 312 F.3d 862, 870 (7th Cir. 2002).
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Conclusion 	1
For the foregoing reasons, the Court finds the search warrant issued here was valid and
supported by probable cause. Accordingly, Defendant Christopher L. Webb’s Motion to Suppress
(Doc. 25) is 	DENIED.
IT IS SO ORDERED.
DATED: March 17, 2026.
STACI M. YANDLE
Chief U.S. District Judge
1 	The Government is correct that mobile homes and other vehicles that can be used as residences fall within the scope
of the automobile exception. 	See California v. Carney, 471 U.S. 386, 393 (1985). However, if the vehicle is within
the curtilage of someone’s home, the automobile exception does not apply. 	Collins v. Virginia, 584 U.S. 586, 596
(2018) (“The automobile exception does not afford the necessary lawful right of access to search a vehicle parked
within a home or its curtilage.”). 	In this case, the camper allegedly being used by Defendant as his residence was
parked on the private property of a third party. Given the Court’s rulings herein, it is not necessary for the Court to
determine whether the automobile exception applies.
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