United States v. Thomas James Savoca
739 F.2d 220, 1984 U.S. App. LEXIS 18410 (1984)
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Rule of Law:
An affidavit supporting a search warrant is insufficient to establish probable cause if it merely states that individuals suspected of a crime were located at the premises to be searched, without providing a sufficient nexus linking that location to evidence of the crime.
Facts:
- Between June 1981 and January 1982, three armed bank robberies occurred in Ohio, with the assailants wearing rubber masks.
- The FBI's investigation into the last robbery, at the Andover Bank, led to the issuance of federal arrest warrants for Thomas James Savoca and James Carey on April 19, 1982, approximately three months after the robbery.
- FBI agents subsequently discovered that Savoca was living in Phoenix, Arizona.
- Through surveillance, agents followed a vehicle from Savoca's residence to the Arizona Ranch House Inn and learned that Room 135 was registered under an alias used by Carey.
- On April 20, 1982, agents observed Savoca and Carey enter Room 135 of the motel.
- Shortly thereafter, as Savoca and Carey exited the room, FBI agents arrested them based on the outstanding federal warrants.
Procedural Posture:
- Following Savoca's arrest, FBI agents obtained a search warrant for his motel room.
- A search of the room produced evidence including handguns, false identification, and masks.
- At Savoca's trial in federal district court, the prosecution introduced this evidence against him.
- Savoca's counsel filed a pre-trial motion to suppress the evidence, arguing the search warrant was invalid for lack of probable cause, but the district court denied the motion.
- A jury convicted Savoca on two counts of bank robbery.
- Savoca, as appellant, appealed his conviction to the United States Court of Appeals for the Sixth Circuit, challenging the district court's denial of his motion to suppress.
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Issue:
Does a search warrant affidavit establish probable cause to search a motel room when it states only that two individuals with outstanding federal arrest warrants for bank robberies that occurred over 2,000 miles away were seen at that location, without providing any specific information linking the motel room to the robberies?
Opinions:
Majority - Contie, Circuit Judge
No. A search warrant affidavit does not establish probable cause to search a location merely by stating that individuals suspected of a crime were present there; it must establish a nexus between the place to be searched and the evidence sought. The affidavit in this case only established that two known bank robbery suspects, wanted for crimes that occurred months prior and over 2,000 miles away, were seen in a motel room. Citing its precedent in United States v. Hatcher, the court emphasized that probable cause to arrest a person does not automatically create probable cause to search a location where they are found. The affidavit failed to provide any facts that would allow a magistrate to reasonably conclude that evidence from the Ohio robberies—such as weapons, disguises, or currency—would be found in the Arizona motel room. Because the affidavit did not specify how much time had passed since the robberies and failed to otherwise connect the location to the crime, it established no more than a "bare suspicion" that evidence would be present, which is insufficient for probable cause.
Analysis:
This decision strongly reaffirms the critical distinction between probable cause to arrest and probable cause to search, preventing the two from being conflated. It clarifies for law enforcement and lower courts that a valid search warrant affidavit must contain specific facts establishing a 'nexus' between the alleged crime, the evidence sought, and the location to be searched. The ruling serves as a check on the power to search, ensuring that a person's presence at a location, even if they are a wanted felon, is not by itself sufficient justification to invade the privacy of that location. This holding reinforces the Fourth Amendment's protection against general warrants and requires a particularized showing of probable cause for every search.
