United States District Court, W.D. Louisiana, Shreveport Division
HORNSBY MAGISTRATE JUDGE
E. WALTER UNITED STATES DISTRICT JUDGE
the Court is a Motion to Suppress filed by Defendant
Christopher John Williams (“Williams”).
See Record Document 19. The Government opposes the
motion. See Record Document 24. For the reasons
assigned herein, the Defendant's motion is
22, 2019, Williams was indicted by the grand jury with one
count of Possession of a Firearm by a Convicted Felon in
violation 18 U.S.C. § 922(g)(1). See Record
Document 1. The federal gun charge was filed after Williams,
who had been arrested and detained on unrelated state
charges, was allegedly heard on the prison's telephone
system directing another individual to dispose of a
firearm. Williams moves to suppress the recorded
conversations underlying his federal charge, arguing that
they are fruit of the poisonous tree because the arrest
warrant issued for one of his state charges was invalid,
which resulted in a warrantless arrest. See Record
Document 19 at 1. Williams contends that law enforcement
would not have been able to listen to his conversations if he
had not been subjected to an unlawful arrest. See
id. at 2-3.
arrest warrant in question was issued by Judge John Mosely, a
District Judge in Caddo Parish, Louisiana, on December 5,
2018. See Record Document 24-2. The arrest warrant
was labeled “State of Louisiana vs. Christopher
Williams B/M 9-21-1988, 149 E. College Street, Shreveport, La
71104.” See Record Document 24-2 at 2. The
warrant read in relevant part as follows:
Sheriff of the Parish of Caddo: -- Greeting -
Whereas, Detective Angie Willhite, badge number #305, has
this day made complaint, under oath, before me, Judge of the
District Court, Parish of Caddo, that on or about the 2nd day
of November, 2018, one Christopher Williams D.O.B. 9-21-1988,
Shreveport, LA at and in said Parish committed the offense of
Attempted Second Degree Murder, in that he violated Louisiana
R.S. 14:27/30.1 in that he had intent to kill a human being.
These are therefore to Command You, in the name of the State
of Louisiana, to forthwith arrest the said B/M DeAndrew
Mosley D.O.B. 02/27/99, Shreveport, LA, and take him before
the District Judge of the Parish of Caddo, to answer unto
said compliant, and to be further dealt with according to
See Record Document 24-2 at 1. The affidavit
submitted to Judge Mosely in support of the warrant lists the
accused as “Christopher Williams B/M 9-21-1988, 149 E.
College Street, Shreveport, La 71104” and contains the
relevant facts supporting the issuance of the warrant.
See id. at 3-5. On the same day, December 5, 2018,
the State of Louisiana Board of Pardons and Parole issued
their own warrant for the arrest of “Christopher J.
Williams, DOC #540061, Black/Male, 09/21/1989” for
violations of his parole conditions. See Record
Document 24-1 at On January 31, 2019, an officer with the
Shreveport Police Department stopped Williams for driving a
vehicle with extremely dark window tint. Williams provided
the officer with an identification card. The officer
performed a check of the National Crime Information Center
system and discovered that Williams had two warrants for his
arrest. Williams was then placed in handcuffs and transported
to jail where he was later overheard on the jail telephone
discussing a firearm.
argues that the warrant issued by Judge Mosely is invalid
because it contains another individual's name (DeAndrew
Mosely D.O.B. 02/27/99). See Record Document 19 at
1. Williams also argues that while his name does appear on
the header of the warrant issued by Judge Mosely, the
birthdate is incorrect. See id. In light of these
errors, Williams contends that the warrant was invalid and
resulted in a warrantless arrest in violation of the Fourth
Amendment. See id. at 1-2.
Fourth Amendment forbids “unreasonable searches and
seizures” such that law enforcement must have either
probable cause or an arrest warrant before securing an
individual in their custody. See Herring v. United
States, 555 U.S. 135, 136, 129 S.Ct. 695, 698 (2009).
However, the Fourth Amendment does not contain a
“provision expressly precluding the use of evidence
obtained in violation of its commands.” Arizona v.
Evans, 514 U.S. 1, 10, 115 S.Ct. 1185 (1995). The
Supreme Court has judicially created “an exclusionary
rule that, when applicable, forbids the use of improperly
obtained evidence at trial.” Herring, 555 U.S.
at 139 (citations omitted). The purpose of the rule is
“to safeguard Fourth Amendment rights generally through
its deterrent effect.” Id. at 140 (citing
United States v. Calandra, 414 U.S. 338, 348, 94
S.Ct. 613 (1974)). Application of the exclusionary rule is
not a necessary consequence of every Fourth Amendment
violation. See id. at 141. Rather, the benefits in
applying the rule to exclude evidence must outweigh the
substantial social costs upon truth-seeking and law
enforcement objectives. See id. (citations omitted).
exclusionary rule does not apply in cases where police acted
in an objectively reasonable manner or in good faith reliance
on a warrant that is subsequently invalidated for a lack of
probable cause. See id. at 142 (citing United
States v. Leon, 468 U.S. 897, 922, 104 S.Ct. 3405
(1984)). Additionally, the exclusionary rule has been found
not to apply “when a warrant was invalid because a
judge forgot to make ‘clerical corrections' to
it.” See id. (citing Massachusetts v.
Sheppard, 468 U.S. 981, 104 S.Ct. 3424 (1984)). The
exclusionary rule was designed to deter police misconduct,
not that of judicial employees. See id. ...