Tenth Circuit US v. Long 13-5082

Decision here.

   Long was arrested after the police served a search warrant on an apartment being used for drug trafficking (Long was in the apartment at the time, along with a gun, a lot of cash, and a lot of cocaine).  In court, he challenged the affidavit for the search warrant.

   The affidavit relied on a confidential informant who had apparently given reliable information in the past.  Long argued that the affidavit did not establish probable cause because the informant did not name him, and because the police didn't corroborate the information the informant had given about the apartment.  The court held that it was unnecessary for the information to name or describe Long, since the informant asserted that there was cocaine in the apartment and the search warrant was directed at the apartment rather than at Long.  The court also held that because the informant had previously given reliable information, this tip was enough to establish probable cause without additional corroboration.

   Long's conviction was upheld.