State v. Tuttle

515 S.W.3d 282 (2017)

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State v. Tuttle

Tennessee Supreme Court
515 S.W.3d 282 (2017)

DC

Facts

In 2012, a state trooper prepared an affidavit for a search warrant of Tuttle’s (defendant) residence and other property. The affidavit included information provided by Davis, a criminal informant, that Tuttle’s son was involved in a drug-trafficking organization. Much of Davis’s information was independently corroborated by officers during the course of the investigation before they sought a search warrant. Officers found drugs, weapons, and large amounts of cash in a search of Tuttle’s property after the warrant was issued. Following his conviction for multiple offenses, Tuttle appealed, arguing that the search-warrant affidavit lacked probable cause because it did not contain facts to establish a nexus between the drugs and his residence. The appellate court applied the Aguilar-Spinelli test to evaluate the search warrant affidavit and found it was insufficient to establish probable cause. The state (plaintiff) then appealed.

Rule of Law

Issue

Holding and Reasoning (Clark, J.)

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