Case Explained: UNITED STATES OF AMERICA v. EARL LEROY GRIFFIN, JR

Court: United States Court of Appeals for the Fourth Circuit Filed: 2026-08-14 The Fourth Circuit reversed the district court’s denial of Earl Leroy Griffin, Jr.’s motion to suppress evidence and vacated his conviction, holding that the search warrant affidavit failed to establish probable cause because it lacked a sufficient nexus between the alleged drug activity and the specific residence searched and contained facts that were too stale. The court applied the *Illinois v. Gates* totality-of-the-circumstances test, requiring a “substantial basis” for the magistrate’s finding of probable cause, which necessitates both a temporal connection (timing) and a factual link (nexus) between the evidence sought and the place to be searched. The court determined the affidavit was deficient because the only concrete allegation of drug activity inside the residence occurred thirteen years prior, rendering it stale, while recent observations described drug transactions in the general “Kent Bottom” area or involved individuals who did not clearly reside at or conduct business from the specific 6740 N. Solomons Island Road address. Furthermore, the court found that the good faith exception to the exclusionary rule did not apply because the affidavit was so lacking in indicia of probable cause that a reasonably well-trained officer would have known it failed to establish a fair probability that evidence would be found at the residence. Consequently, the case is remanded for further proceedings consistent with this opinion, effectively barring the admission of the seized evidence and undermining the basis for the defendant’s conviction. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.