The U.S. Court of Appeals for the Tenth Circuit issued an order and judgment on Jan. 2, 2026, reversing a lower court's suppression ruling in a federal criminal case involving alleged FBI impersonation and firearms violations.
Michael Brandon Williams was indicted by a federal grand jury on two counts: impersonating an FBI agent and being a felon in possession of a firearm and ammunition. The charges stem from an incident that occurred on Sept. 26, 2024, at Bixby East Elementary and Intermediate School in Broken Arrow, Oklahoma, where Williams and other parents were waiting to pick up their children.
The U.S. District Court for the Northern District of Oklahoma initially granted Williams' motion to suppress evidence seized from his home. However, the government appealed the suppression order, leading to the Tenth Circuit's review of the case.
Exercising interlocutory jurisdiction under 18 U.S.C. § 3731, the three-judge panel consisting of Circuit Judges Matheson, Carson, and Rossman reversed the district court's determination. The appellate court held that the good-faith exception to the exclusionary rule applies in this case, effectively allowing the government to use the suppressed evidence in its prosecution of Williams.
The good-faith exception is a legal doctrine that permits the use of evidence obtained through searches that violate the Fourth Amendment when law enforcement officers acted in objective good faith in relying on a search warrant. This exception was established by the Supreme Court in *United States v. Leon* (1984) and allows courts to admit evidence when officers reasonably relied on a warrant that was later found to be invalid.
The Tenth Circuit's decision represents a significant victory for federal prosecutors, who can now proceed with their case against Williams using evidence that had been previously excluded. The ruling also demonstrates the appellate court's willingness to apply established exceptions to the exclusionary rule when law enforcement officers acted in good faith.
The case highlights the ongoing tension between Fourth Amendment protections against unreasonable searches and seizures and the government's interest in prosecuting federal crimes. The exclusionary rule, which generally prohibits the use of illegally obtained evidence, serves as a deterrent to police misconduct but can sometimes result in the suppression of probative evidence in criminal cases.
Williams faces serious federal charges that carry substantial penalties. Impersonating a federal agent is a federal crime under 18 U.S.C. § 912, punishable by up to three years in prison. The charge of being a felon in possession of firearms and ammunition, prosecuted under 18 U.S.C. § 922(g), can result in up to 10 years imprisonment for individuals with prior felony convictions.
The timing of the incident at an elementary school raises additional concerns about public safety and the potential impact on the school community. Federal authorities take impersonation of law enforcement officers particularly seriously, as such conduct can undermine public trust in legitimate law enforcement activities and create confusion about official authority.
The Tenth Circuit's order explicitly states that the ruling "is not binding precedent, except under the doctrines of law of the case, res judicata, and collateral estoppel." However, the court noted that the decision "may be cited for its persuasive value consistent with Fed. R. App. P. 32.1 and 10th Cir. R. 32.1."
This designation means that while the ruling resolves the immediate dispute in Williams' case, it does not establish new circuit precedent that would bind future panels. Nevertheless, the decision provides guidance on how the Tenth Circuit views the application of the good-faith exception to the exclusionary rule in similar circumstances.
The case will now return to the district court, where prosecutors can proceed with their case against Williams using the previously suppressed evidence. Williams' defense team will need to develop new strategies for challenging the government's evidence and defending against the federal charges.
The reversal also underscores the importance of the government's ability to appeal adverse rulings in criminal cases under specific circumstances. The interlocutory appeal statute, 18 U.S.C. § 3731, allows the government to appeal certain pretrial orders that would effectively terminate the prosecution, ensuring that legal errors by trial courts can be corrected before cases proceed to trial.
As the case moves forward in the district court, it will serve as a test of how courts balance law enforcement interests with constitutional protections in cases involving alleged impersonation of federal agents. The outcome may influence how similar cases are prosecuted and defended in the Tenth Circuit's jurisdiction, which includes Colorado, Kansas, New Mexico, Oklahoma, Utah, and Wyoming.
The Williams case demonstrates the complex interplay between Fourth Amendment jurisprudence and federal criminal prosecution, particularly in cases where the validity of search warrants and the good-faith reliance of law enforcement officers become central issues in determining the admissibility of crucial evidence.