## Facts

- Thomas James Savoca was investigated for a series of armed bank robberies in Ohio and later charged under 18 U.S.C. § 2113(a), (d).
- Federal arrest warrants issued for Savoca and an alleged confederate in connection with a bank robbery investigation.
- FBI agents located Savoca in Phoenix, Arizona, conducted surveillance, and connected him to a motel room registered under an alias linked to the alleged confederate.
- Agents arrested Savoca and the other suspect after observing them enter and exit the motel room.
- Agents then obtained a warrant to search the motel room; the supporting affidavit relied largely on the suspects’ outstanding bank-robbery warrants and their presence in the room.
- The affidavit did not provide specific, current facts tying the motel room to fruits or instrumentalities of the Ohio robberies beyond occupancy.
- The search produced items such as firearms, masks, and identification materials, which were used against Savoca at trial.
- Savoca was convicted in federal district court, and the motel-room evidence was a substantial component of the prosecution’s case.

## Issues

1. Whether the warrant affidavit established probable cause by showing a sufficient nexus between the motel room and evidence of the charged robberies.
2. If probable cause was lacking, whether the exclusionary rule nevertheless permitted admission of the seized evidence under the good-faith exception recognized in United States v. Leon.

## Decision

- The Sixth Circuit treated the warrant affidavit as insufficient to establish probable cause under its nexus analysis.
- The court held that the Leon good-faith exception applied because the agents’ reliance on the magistrate-issued warrant was objectively reasonable.
- The court declined to suppress the motel-room evidence.
- The practical effect was to uphold (or restore) Savoca’s convictions rather than require a new trial based on suppression.

## Legal Principles

- A search-warrant affidavit must provide facts creating a fair probability that evidence of a specific crime will be found in the particular place to be searched; mere suspect status and presence at a location, without more, may be inadequate.
- Under United States v. Leon, evidence obtained pursuant to a warrant later found invalid is generally admissible if officers acted in objectively reasonable reliance on the warrant issued by a neutral magistrate.
- Suppression is inappropriate where officers seek and execute a facially valid warrant and the affidavit is not so lacking in indicia of probable cause that reliance would be unreasonable.

## Conclusion

The Sixth Circuit concluded that, although the motel-room warrant lacked a sufficient factual nexus to establish probable cause, the agents’ objectively reasonable reliance on the magistrate’s warrant brought the search within Leon’s good-faith exception, so suppression was denied and the convictions were allowed to stand.


United States v. Savoca, 761 F.2d 292 (6th Cir. 1985)