The U.S. Court of Appeals for the Sixth Circuit has affirmed a drug trafficking conviction in *United States v. Orlando Bernard Easter*, rejecting the defendant's argument that police lacked probable cause for searches that uncovered a large cache of drugs and weapons.
Chief Judge Jeffrey Sutton, writing for a three-judge panel that included Circuit Judges Danny Boggs and Amul Bloomekatz, upheld the district court's denial of Easter's motion to suppress evidence obtained from searches of his storage unit and his girlfriend's residence.
The case stems from a January 2024 investigation into Easter's alleged heroin and fentanyl trafficking operation. Law enforcement coordinated at least three controlled drug purchases between Easter and a confidential informant, establishing a pattern of drug trafficking activity.
During surveillance operations preceding one of the controlled buys, police observed Easter driving his gold Chevrolet Impala from his girlfriend's house to an open-air self-storage facility. Officers watched as Easter entered a code into a keypad to access the facility and then exited a short time later. Police noted that Easter appeared to live at his girlfriend's home with her and their children.
Based on the controlled purchases and other evidence gathered during the investigation, law enforcement obtained search warrants for both Easter's storage unit and his girlfriend's residence. The subsequent searches revealed what the court described as "a large cache of drugs and guns."
Easter challenged the searches in the U.S. District Court for the Western District of Michigan, arguing that police lacked probable cause to obtain the search warrants. The district court rejected this argument and denied Easter's motion to suppress the evidence.
On appeal to the Sixth Circuit, Easter continued to contest the validity of the search warrants, maintaining that the evidence used to support them was insufficient to establish probable cause. The appeals court disagreed, finding that the controlled drug purchases and surveillance evidence provided adequate justification for the searches.
The court's opinion, filed Jan. 2, 2026, was marked "not recommended for publication," indicating that while it resolves the specific case, it may have limited precedential value for future cases. Such designations are typically reserved for decisions that apply established legal principles to specific facts without breaking new legal ground.
The case illustrates the ongoing use of confidential informants in drug trafficking investigations and the courts' general acceptance of controlled buy operations as a basis for establishing probable cause. The ability of law enforcement to coordinate multiple controlled purchases helped strengthen their case for obtaining search warrants in this instance.
The investigation's focus on both Easter's storage facility and his residence reflects common patterns in drug trafficking cases, where defendants often use multiple locations to store drugs and related materials. The discovery of both drugs and firearms during the searches is typical in such cases, as drug trafficking operations frequently involve weapons.
Easter's challenge to the search warrants centered on the fundamental Fourth Amendment requirement that police must have probable cause before conducting searches. Probable cause exists when facts and circumstances would lead a reasonable person to believe that evidence of a crime will be found in the location to be searched.
The Sixth Circuit's affirmance suggests that the controlled drug purchases, combined with the surveillance observations of Easter's movements between his residence and the storage facility, provided sufficient evidence to meet this probable cause standard.
The case was heard on appeal from the Western District of Michigan, which covers the western portion of the state and has seen numerous drug trafficking prosecutions as law enforcement continues to combat the opioid crisis affecting the region.
For Easter, the appeals court's decision means his conviction stands, and the evidence obtained from the challenged searches remains admissible. The court's ruling reinforces the legal framework that allows law enforcement to use controlled drug purchases as a foundation for obtaining search warrants in trafficking investigations.
The decision also demonstrates the courts' continued willingness to uphold convictions based on traditional investigative techniques involving confidential informants, provided that law enforcement follows proper procedures in establishing probable cause for searches.
With the Sixth Circuit's affirmance, Easter's options for further appeal would be limited to seeking review from the Supreme Court, though the high court accepts only a small percentage of cases for review and typically focuses on issues of broader legal significance.