## Facts

- Law enforcement obtained a warrant to search a mobile home and surrounding property at 4571 Dugger Road in Culleoka, Tennessee, including outbuildings and vehicles on the premises.
- The warrant affidavit, prepared by a state trooper, relied on surveillance and informant information linking the location to a drug-trafficking conspiracy; officers also corroborated aspects of the tips through investigation.
- During execution of the warrant, officers seized drugs (including marijuana and cocaine), scales, a money counter, firearms, and large amounts of cash from the residence.
- Officers also searched a Honda Civic on the property and found additional firearms and over $1,000,000 in cash in an ammunition can in the trunk.
- A jury convicted Jerry Lewis Tuttle of multiple offenses, including conspiracy to possess over 300 pounds of marijuana with intent to sell or deliver and conspiracy to commit money laundering.
- The trial court ordered forfeiture of $1,098,050 in seized cash.
- The intermediate appellate court held the affidavit did not establish probable cause under then-controlling Tennessee precedent, ordered suppression, vacated the conspiracy convictions, but upheld forfeiture of the cash.

## Issues

1. What standard governs whether an affidavit establishes probable cause for a search warrant under article I, section 7 of the Tennessee Constitution: the Aguilar–Spinelli-based approach previously used in Tennessee or the federal totality-of-the-circumstances test.
2. Under the proper standard, whether the warrant affidavit provided a sufficient basis for probable cause.
3. Whether the evidence was sufficient to support the defendant’s conspiracy convictions.
4. Whether forfeiture of the seized cash was proper.

## Decision

- The Tennessee Supreme Court overruled prior state precedent requiring an Aguilar–Spinelli-style analysis and adopted the Illinois v. Gates totality-of-the-circumstances test for article I, section 7.
- Applying that test, the Court held the affidavit established probable cause and reversed the ruling invalidating the warrant.
- The Court reversed the intermediate court’s insufficiency determination and reinstated the conspiracy convictions and the trial court’s judgments approving the jury verdicts.
- The Court affirmed the forfeiture of $1,098,050 in cash, but on different reasoning than the intermediate appellate court.

## Legal Principles

- Probable cause for a warrant under article I, section 7 is evaluated under the totality of the circumstances; informant “veracity” and “basis of knowledge” remain relevant considerations but are not rigid, independent prerequisites.
- A magistrate’s probable-cause decision is a practical, common-sense determination whether the affidavit shows a fair probability that contraband or evidence of a crime will be found in the place to be searched.
- Corroborated informant information, surveillance, and investigative details may collectively supply a substantial basis for a finding of probable cause even if individual components are imperfect.
- For conspiracy offenses, a combination of large quantities of drugs, cash, tools associated with drug distribution, and surrounding circumstances may permit a rational trier of fact to find guilt beyond a reasonable doubt.
- Forfeiture of seized funds is proper when the evidence supports a connection between the money and illegal drug activity and statutory procedural requirements are satisfied.

## Conclusion

The Tennessee Supreme Court replaced the state’s prior informant-focused warrant test with the Gates totality-of-the-circumstances approach, upheld the search warrant and reinstated drug-conspiracy convictions, and affirmed forfeiture of over $1 million in cash linked to drug trafficking.


State v. Tuttle, 515 S.W.3d 282 (Tenn. 2017)