The U.S. Court of Appeals for the Third Circuit affirmed the conviction and 120-month prison sentence of Leroy Irvin, who pleaded guilty to federal charges of possessing fentanyl with intent to distribute. The court issued a non-precedential opinion on Jan. 14, rejecting Irvin's appeal of evidence suppression rulings by the district court.
Irvin entered a conditional guilty plea admitting to possessing with intent to distribute substances containing detectable amounts of fentanyl, violating federal drug laws under 21 U.S.C. §§ 841(a)(1), 841(b)(1)(A)(vi), and 841(b)(1)(B)(vi). The conditional plea allowed him to preserve his right to challenge the U.S. District Court for the Western District of Pennsylvania's denial of several pre-trial motions.
The case originated from a June 19 incident involving gunfire detected by ShotSpotter technology at a Pittsburgh housing complex. At 8:23 p.m., the acoustic detection system identified 17 rounds of gunfire by multiple shooters at 1717 Belleau Drive, part of a Pittsburgh housing complex. One minute later, a second ShotSpotter alert reported nine additional rounds fired at 1728 Belleau Drive.
Sergeant Emily Myers responded to the scene as part of the police investigation that followed the gunfire detection. The subsequent investigation led to search warrants being executed, which uncovered evidence that formed thebasis for the federal drug charges against Irvin.
Irvin's legal team challenged the evidence obtained through the search warrants, filing multiple motions to suppress the evidence before District Judge Cathy Bissoon. The defense also sought a Franks hearing, a procedure that allows defendants to challenge the truthfulness of statements made in search warrant affidavits. Judge Bissoon denied both the motion for a Franks hearing and the three separate motions to suppress evidence.
Following his conditional guilty plea, Irvin was sentenced to 120 months in federal prison for the fentanyl distribution charges. The 10-year sentence reflects the serious nature of fentanyl trafficking under federal sentencing guidelines, which treat the synthetic opioid as particularly dangerous due to its potency and role in the ongoing overdose crisis.
Irvin filed a timely appeal to the Third Circuit, challenging the district court's evidentiary rulings. His appeal focused on the denial of his suppression motions and the refusal to grant a Franks hearing regarding the search warrant applications. The defense argued that evidence obtained through the search warrants should have been excluded from his case.
The three-judge panel consisting of Circuit Judges Stephanos Bibas, Anthony Scirica, and Joseph Smith heard the case under Third Circuit Local Appellate Rule 34.1(a), which governs certain streamlined appeal procedures. The case was submitted for decision on Oct. 31, 2025, without oral arguments.
Circuit Judge Smith authored the opinion for the panel, which unanimously rejected Irvin's arguments and affirmed the lower court's rulings. The court's decision validates the district court's handling of the suppression motions and confirms that the search warrants were properly executed and the resulting evidence admissible.
The opinion carries a "not precedential" designation, meaning it does not establish binding legal precedent for future Third Circuit cases. Under the court's Internal Operating Procedures, such dispositions do not constitute binding authority, though they may still provide guidance on how similar cases might be resolved.
The case highlights the intersection of modern crime detection technology and traditional Fourth Amendment protections. ShotSpotter systems use acoustic sensors to detect and locate gunfire in real time, providing law enforcement with immediate alerts about shooting incidents. The technology has become increasingly common in urban areas as police departments seek to respond more quickly to gun violence.
Fentanyl trafficking cases have become a priority for federal prosecutors as the synthetic opioid continues to drive record overdose deaths across the United States. The Drug Enforcement Administration has identified fentanyl as the leading cause of overdose fatalities, with even small quantities proving lethal due to the drug's extreme potency.
The charges against Irvin fell under federal drug trafficking statutes that carry mandatory minimum sentences for certain quantities of controlled substances. The specific violations cited in his case cover both the basic offense of possession with intent to distribute and enhanced penalties that apply when fentanyl is involved.
With the Third Circuit's affirmation, Irvin's conviction and sentence become final unless he seeks further review from the Supreme Court. The high court reviews only a small fraction of cases through the certiorari process, typically focusing on cases that present novel legal questions or conflicts between different federal circuits.
The Western District of Pennsylvania, where the case originated, has been active in prosecuting fentanyl distribution cases as part of federal efforts to combat the opioid crisis. District courts in areas heavily affected by the overdose epidemic have handled increasing caseloads of federal drug prosecutions targeting fentanyl trafficking networks.
