Palma Jefferson, Jr. v. United States

I. Fourth Amendment: Warrant and Entry Defects

1. Whether the Fourth Amendment's probable cause requirement is satisfied when a search warrant issues based on an affidavit lacking objective facts, and whether a district court's refusal to address this constitutional challenge conflicts with this Court's precedents requiring meaningful judicial review of Fourth Amendment claims, including Beck v. Ohio, 379 U.S. 89 (1964); Johnson v. United States, 333 U.S. 10 (1948); and Ybarra v. Illinois, 444 U.S. 85 (1979).

2. Whether the Fourth Amendment is violated when law enforcement officers gain entry to a residence by falsely representing to a property manager that they possessed a warrant when in fact no warrant had been applied for or issued, and subsequently obtain evidence before execution of any warrant, as substantiated by photographic timestamps, corroborating police dispatch logs, and sworn testimony; and whether due process is violated when the government falsely attributes the warrantless search to a "daylight savings setting" not found in the camera's user manual, contradicted further by VeriPic's metadata confirmation that the internal camera clock was accurate at the time of upload, and the district court refuses to conduct any legal analysis or fact-finding of this challenge.

3. Whether the Fourth Amendment and the Sixth Amendment Confrontation Clause are violated when a warrant affidavit, and suppression-hearing testimony describe information from a "reliable source," even further supported by the police reports as a "reliable confidential source," and the government later recharacterizes that source as an "anonymous tip" at trial, and the district court upholds the warrant without addressing the contradiction or affording the defendant an opportunity to confront or test the credibility of the source—even though the information attributed to that source never materialized and demonstrated unreliability—contrary to this Court's precedents in Illinois v. Gates, 462 U.S. 213 (1983); Florida v. J.L., 529 U.S. 266 (2000); Crawford v. Washington, 541 U.S. 36 (2004); and Napue v. Illinois, 360 U.S. 264 (1959).