United States v. Savoca

Three bank robberies were committed in Ohio between June 1981 and January 1982 by armed men wearing masks. After an investigation by the Federal Bureau of Investigation (FBI), arrest warrants were issued in April 1982 for one of the robberies for Thomas Savoca (defendant) and an accomplice, James Carey. The FBI discovered that Savoca was living in Arizona, staked out his house, and followed a vehicle from the house to a nearby motel. The agents found that Savoca and Carey were both in a room at the motel. Savoca and Carey were arrested as they left the motel room. Following the arrest, the FBI secured a search warrant to search the motel room for weapons, money, disguises, and false identification. The FBI obtained the search warrant based on an affidavit that provided that Savoca and Carey had been arrested for a bank robbery in Ohio and were suspected in other bank robberies in that state, without specifying that the robberies had occurred months before, and that Savoca and Carey had been seen together in the motel room. During the search the authorities found handguns, false identification, and masks in the room. Savoca was convicted of two counts of bank robbery. Savoca appealed, alleging that the search warrant was invalid because the supporting affidavit did not establish probable cause that evidence of a crime would be found in the motel room.