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6th Circuit Affirms Drug Conviction After Anonymous Tip Led to Car Search

The U.S. Court of Appeals for the Sixth Circuit affirmed a drug conviction against Steven Tilden Fellmy, rejecting his argument that methamphetamine found in his car should have been suppressed because officers conducted an unlawful search using a police dog.

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4 min readcourtlistener
Seal of the Sixth Circuit Court of Appeals

Case Information

Case No.:
No. 25-5381

Key Takeaways

  • Sixth Circuit affirmed conviction after rejecting argument that methamphetamine evidence should have been suppressed
  • Case began with anonymous tip about drug transportation in silver Ford Mustang through Kentucky
  • Two judges wrote separate concurring opinions spanning 22 pages of additional analysis
  • Decision recommended for publication, establishing precedent for future Fourth Amendment cases

The U.S. Court of Appeals for the Sixth Circuit affirmed a criminal conviction against Steven Tilden Fellmy in a case involving the discovery of methamphetamine during a traffic stop that began with an anonymous tip. The court issued its decision on Jan. 23, 2026, in *United States v. Steven Tilden Fellmy* (6th Cir. 2026).

The case originated in the U.S. District Court for the Eastern District of Kentucky at Lexington, where District Judge Karen K. Caldwell presided over the criminal proceedings under case number 5:24-cr-00006-1. Fellmy appealed his conviction, arguing that evidence obtained during the search should have been suppressed.

According to the per curiam opinion delivered by the three-judge panel, Deputy Michael Raisor received an anonymous tip indicating that a man named Steven Fellmy was transporting drugs through Mercer County, Kentucky, in a silver Ford Mustang with a black roof. Acting on this information, law enforcement officers located and stopped Fellmy's vehicle.

During the traffic stop, officers used a police dog to search the vehicle, which led to the discovery of a large quantity of methamphetamine. This discovery formed the basis of the criminal charges against Fellmy, who was subsequently prosecuted in federal court.

Fellmy's primary argument on appeal centered on Fourth Amendment protections against unreasonable searches and seizures. He contended that the officers' use of a police dog to search his vehicle constituted an unlawful search, and therefore the methamphetamine evidence should have been suppressed under the exclusionary rule. The exclusionary rule prevents prosecutors from using evidence obtained through violations of a defendant's constitutional rights.

The Sixth Circuit panel, consisting of Circuit Judges Griffin, Thapar, and Hermandorfer, rejected Fellmy's suppression argument and affirmed his conviction. The court's per curiam opinion found that the search was conducted lawfully, though the full reasoning for this conclusion was not detailed in the available excerpt.

The case garnered additional attention from two members of the panel, who authored separate concurring opinions. Circuit Judge Thapar wrote a concurring opinion spanning pages 12 through 26 of the decision, while Circuit Judge Hermandorfer authored a separate concurrence covering pages 27 through 34. These additional opinions likely address specific legal issues or provide expanded reasoning for the court's holding, though their specific content was not available.

The legal representation in the case included Jeffrey C. Rager of Rager Law Firm, PLLC, based in Lexington, Kentucky, who served as counsel for appellant Fellmy. The government was represented by Charles P. Wisdom Jr. from the U.S. Attorney's Office in Lexington, Kentucky.

The decision carries particular weight as it was recommended for publication pursuant to Sixth Circuit Internal Operating Procedure 32.1(b), indicating that the court views the ruling as having precedential value for future cases involving similar legal issues.

Fourth Amendment jurisprudence regarding vehicle searches and the use of drug-detection dogs has evolved significantly in recent years. The Supreme Court's decisions in cases such as *Rodriguez v. United States* (2015) have established that prolonging a traffic stop for a dog sniff constitutes a seizure that must be justified by reasonable suspicion. However, courts continue to grapple with the specific circumstances under which such searches are permissible.

The Sixth Circuit's jurisdiction includes Kentucky, Michigan, Ohio, and Tennessee, meaning this decision will serve as binding precedent for federal courts within those states. The ruling may influence how law enforcement agencies in the region conduct vehicle searches based on anonymous tips and how defense attorneys challenge such evidence.

Anonymous tips present particular challenges in Fourth Amendment analysis, as courts must balance law enforcement's need to investigate credible information against individuals' rights to be free from unreasonable government intrusion. The reliability and specificity of anonymous tips often determine whether they provide sufficient justification for police action.

The case number 25-5381 indicates this was among the appeals decided by the Sixth Circuit during the 2025 term, reflecting the ongoing volume of criminal appeals that federal courts of appeals handle annually. Drug-related prosecutions continue to represent a significant portion of federal criminal cases, particularly in regions affected by the ongoing opioid and methamphetamine crises.

Fellmy's conviction now stands affirmed, though he may still have options for further appeal to the Supreme Court, depending on the specific legal issues involved and whether they present questions of national importance warranting high court review. The decision demonstrates the continued importance of Fourth Amendment protections in drug enforcement cases while affirming law enforcement's authority to conduct searches under appropriate circumstances.

Topics

drug traffickingFourth Amendmentsearch and seizurepolice dog searchestraffic stopsmethamphetamine possession

Original Source: courtlistener

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