United States v. Hearn

What This Case Is About

United States v. Hearn is a federal criminal case involving the arrest of Gregory Hearn, Joel Hammond, and Cassandra Collins on methamphetamine charges. While not a § 1983 civil rights case, Hearn is significant because it addresses Fourth Amendment standards for probable cause, the use of confidential informants, and the circumstances under which evidence seized during or after an arrest will be upheld. These principles directly apply to civil rights cases challenging the legality of arrests and searches.

The Facts

In March 2007, officers of the Caddo Parish Sheriff’s Office received information from two confidential informants that Hearn and Brad Blanton were selling methamphetamine from room 1711 of the El Dorado Casino Hotel. The second informant agreed to wear an audio transmitter and participate in an undercover purchase from the suspects. Officers set up peephole surveillance of the suspects’ room from the room directly across the hall.

After furnishing the informant with cash to make a controlled purchase, officers waited with the informant in the hotel parking lot while she attempted to make phone contact with the suspects. The informant successfully made a controlled buy, and officers subsequently arrested the defendants.

The defendants moved to suppress all evidence seized during and shortly after their arrests, arguing that the searches and seizures violated the Fourth Amendment. The district court denied the motions to suppress, finding that the arrests were supported by probable cause and that the subsequent searches were lawful.

What the Court Decided

The Fifth Circuit affirmed the district court’s denial of the motions to suppress.

The court held that the officers had probable cause to arrest the defendants based on the totality of the circumstances: information from two independent confidential informants, a controlled purchase using a wired informant, and direct surveillance of the suspects’ hotel room. The court found that this combination of evidence established more than sufficient probable cause.

On the search issues, the court upheld the seizure of evidence found during and immediately after the arrests as lawful searches incident to arrest and under exigent circumstances. The court noted that the officers’ surveillance operation was methodical and well-documented, supporting the reliability of the evidence obtained.

Why This Case Matters for Your § 1983 Case

Confidential informant tips can establish probable cause. When officers rely on information from confidential informants to make an arrest, courts evaluate the informant’s reliability and whether the information was corroborated by independent investigation. If the informant’s tip is confirmed through controlled purchases or surveillance, probable cause is typically established.

Probable cause from the totality of circumstances. Courts do not evaluate each piece of evidence in isolation. Multiple sources of information—informant tips, surveillance, controlled buys—are considered together. This means challenging probable cause requires showing that the entire body of evidence was insufficient, not just picking apart individual components.

Evidence seized incident to a lawful arrest is generally admissible. If officers have probable cause for the arrest, evidence discovered during the arrest and immediately afterward is typically upheld. For § 1983 plaintiffs alleging unlawful arrest, this means the legality of the arrest itself is the key battleground.

Key Takeaway

United States v. Hearn demonstrates that when law enforcement builds a case using multiple investigative techniques—confidential informants, controlled purchases, and surveillance—the resulting probable cause is robust and difficult to challenge. For § 1983 plaintiffs alleging false arrest, understanding how officers established probable cause through these methods is critical to evaluating whether a viable claim exists.