When Reliable Isn’t Enough: Why Nagle Was Suppressed and Long Wasn’t

Cases Compared:

State v. Nagle, No. A23-0927 (Minn. Oct. 22, 2025)

United States v. Long, No. 24-3377 (6th Cir. Oct. 17, 2025)

TL;DR

Holding (Nagle): Minnesota’s high court suppressed evidence from a home search based solely on an uncorroborated informant tip.

Holding (Long): The Sixth Circuit upheld a home search based on a pattern of corroborated surveillance and drug activity.

Importance: These two cases, decided just days apart, show the razor-thin line between probable cause that fails and probable cause that holds up.

Limits: Reliable informants help—but they aren’t magic. Without corroboration, continuity, and connection to current activity, a warrant can crumble.

Facts in Both Cases

State v. Nagle (Minnesota, 2025) A Willmar officer applied for a warrant after a confidential reliable informant (CRI) said they’d seen people smoking meth in Jennifer Nagle’s house 72 hours before. No. officer surveillance, no follow-up, no corroboration—just a bare tip. A warrant was issued, meth residue found, and Nagle was convicted. The Minnesota Supreme Court reversed, holding that a one-time, unverified tip didn’t meet the “fair probability” standard for probable cause.

United States v. Long (Sixth Circuit, 2025) DEA task force officers spent months investigating Devin Long, a mid-level supplier in a meth and fentanyl operation. They tied his vehicle and home to repeated controlled buys, stash house visits, and one street-level drug handoff observed outside his residence. Officers obtained a search warrant, found narcotics and guns, and Long’s conviction was affirmed on appeal. The court found ample probable cause under the “known drug dealer” doctrine and the totality of the circumstances.

Issues and Outcomes

Legal Question	Nagle (Suppressed)	Long (Upheld)
Did the warrant show a fair probability that evidence would be found?	No – One unverified, 72-hour-old tip is too thin.	Yes – Continuous trafficking behavior linked to the home established probability.
Was the informant reliable?	Yes, but reliability alone wasn’t enough.	Yes, and corroborated by officer observation.
Was there corroboration?	None.	Multiple layers: surveillance, trash pulls, vehicle patterns.
Was the activity ongoing?	One isolated use event.	Continuous trafficking.
Result	Evidence suppressed.	Warrant upheld.

Court’s Reasoning

Nagle: “Too Little, Too Late” The tip’s content was too limited: one observation of drug use by unnamed individuals. The timing was stale—72 hours with no proof of continued activity. The lack of corroboration left no basis for a reasonable inference that contraband remained. Reliable informant ≠ probable cause without supporting facts.

Long: “Pattern and Probability” Investigators demonstrated continuity—repeated drug transactions and vehicle movements tied to Long’s home. Officers corroborated tips with surveillance and physical evidence. The home nexus was solid: activity outside the house supported inference of contraband inside. The totality easily met the “fair probability” threshold.

Street Takeaways

1. Corroboration Counts: Reliable informants are only as good as the evidence that backs them up. Verify, observe, and document.

2. Continuity Builds Confidence: Repeated or ongoing conduct beats a single event every time. “Once” looks accidental—“often” looks criminal.

3. Connect the Home: Always tie your target location to current or continuing crime. Courts want a clear nexus between the suspect’s home and the illegal activity.

4. Don’t Rely on Titles Alone: “Confidential Reliable Informant” sounds strong—but without fresh, corroborated details, it’s paper-thin in court.

5. Document the Bridge: A good affidavit doesn’t just state what you saw—it connects the dots. Dates, times, repeated behavior, prior intel—spell it out.

Why This Comparison Matters

These cases show how two judges, looking at two warrants, can reach opposite conclusions under the same legal rule. The difference wasn’t law—it was work. Nagle stopped with an unverified tip; Long built a record of corroborated activity. That’s the margin between suppression and conviction.

Training Recap

Probable cause is built, not assumed.

In Nagle, the warrant fell apart because the officer trusted the informant without checking the story. In Long, investigators layered months of corroboration into a solid, defensible affidavit.

The lesson for officers and detectives: if you rely on a CRI, treat their tip like a lead, not proof. Follow it, verify it, and build your probable cause step by step.

Disclaimer

This training brief is for informational and educational purposes only to help law enforcement understand developing Fourth Amendment law. It does not constitute legal advice and should not be relied upon for courtroom testimony or operational decisions.