Raymond Ronald Jennings v. United States

In Illinois v. Gates, 462 U.S. 213 (1983), this Court held that an informant’s "veracity", "reliability", and "basis of knowledge" are all highly relevant in determining the value of bis or her report in showing probable cause for the issuance of a search warrant. Illinois v. Gates, 462 U.S. 213 (1983). When an officer omits information from the probable cause aff­ idavit about an informant's credibility is sufficient to raise an inference of reckless disregard for the truth that could undermine the good faith exception under United States v. Leon, 468 U.S. 897 (1984). In this case, the Court of Appeals For The Fourth Circuit did acknowledge that two informants only "implicated Jennings" and "that even in the absence of probable cause, the evidence from Jennings' home would be admissible because the officers relied in good faith on a search warrant in conducting their search." Despite these findings, the Court of Appeals found no Gates, nor a Leon violation because of good faith. The question presented is; Did the officer omit from his probable cause affidavit information concerning the two informant's credibility that cou infer reckless disregard for the truth that could undermine the good faith exception?