When “Trusted” Informants Sink a Warrant: What United States v. Felton Teaches Officers About Affidavits, Omissions, and GPS Trackers

In law enforcement, we rely heavily on confidential informants. Many times, they’re the difference between having a good hunch and having actual probable cause. But the Seventh Circuit’s decision in United States v. Felton (2025) gives us an important reminder: if your warrant affidavit leans on an informant, you must tell the judge the whole story — not just the parts that help you.

This case walks through what happens when officers omit key credibility details, fail to corroborate drug activity, and rely too heavily on a single source. The result? A reversal, a remand, and a mandatory Franks hearing to examine whether the affiant acted intentionally or recklessly.

Let’s break down what happened and what lessons every officer can apply immediately.

The Case: A GPS Tracker Based on an Informant’s Tip

Investigators received a tip from a confidential source (CS) claiming that Donald Felton was making routine methamphetamine runs from Taylorville, Illinois to St. Louis. The CS gave specifics:

• Felton usually drove his girlfriend’s white Mazda SUV

• He typically bought 2–3 ounces at a time

• He had been stopped recently with a “starter pistol” and a wad of cash

Inspector Brown attempted to corroborate the tip. He confirmed who owned the SUV, that Felton had previously been stopped in it, and that a deputy recalled seeing cash and a blank-firing weapon. He then applied for a warrant to install a GPS tracker on the SUV. The judge issued the warrant.

Three days after installing the tracker, officers saw Felton driving toward St. Louis. When he returned, they stopped him for a missing front license plate. A K-9 alerted, a search followed, and methamphetamine was found.

Felton was charged federally — and immediately challenged the warrant.

Where Things Went Wrong: What the Affidavit Left Out

The affidavit told the judge that the CS had been reliable before and had a felony burglary conviction.

What it didn’t disclose was far more important:

• The informant had been paid $345 for the Felton information.

• He had been cooperating since 2013 to get leniency on his own charges — and his friends’.

• Officers found suspected meth in his home shortly before he snitched.

• He had a pending meth possession charge at the time.

• He had eight arrests and multiple convictions, including for assault and interfering with the courts.

  
  

These details go directly to motivation — and credibility. The judge never saw any of this.

The Seventh Circuit: Probable Cause Fails Without Full Disclosure

The court explained that if your warrant is almost entirely based on an informant’s tip, the judge must be fully informed about:

• how the informant knows the information, and

• whether the informant is credible, biased, or motivated by self-interest.

In Felton’s case, the affidavit didn’t say how the CS knew about the drug runs. It didn’t show the CS had firsthand knowledge. It didn’t explain the relationship between the CS and Felton. And most importantly — it didn’t give the judge any of the red flags about the CS’s criminal history, pending charges, payments, or incentive to lie.

Because the affidavit lacked both corroboration of drug activity and key credibility information, the court said it simply wasn’t enough to establish probable cause for installing a GPS tracker. And when significant credibility information is omitted, a Franks hearing is required to see whether the omissions were reckless or intentional. The case was reversed and remanded.

Training Points for Officers

Here are the practical, street-ready lessons the Felton case gives us:

1. Don’t withhold credibility information — ever.

Judges should know about:

• payments

• cooperation deals

• pending charges

• prior arrests

• motive to lie

• if it affects credibility, disclose it

  
  

2. Corroborate the criminal activity, not just innocent facts.

Confirming the car’s owner or seeing a wad of cash isn’t corroboration of drug trafficking. Courts want criminal corroboration — controlled buys, surveillance, admissions, or actual evidence of drug activity.

3. Basis of knowledge matters.

Explain how the informant knows what they claim.“Felton drives to St. Louis to buy meth” is meaningless unless the CS explains how they know.

4. GPS trackers require strong probable cause.

This isn’t a “light” warrant. It’s a full Fourth Amendment search. Make sure the affidavit is solid.

5. Selective omissions can get your case reversed.

If you omit facts that hurt the informant’s credibility, a court may infer reckless disregard for the truth — and order a Franks hearing.

6. Good-faith won’t save an affidavit that misleads the judge.

The Leon exception does not apply when omissions are reckless or intentional.

7. Transparency protects your investigation.

Judges don’t want perfect affidavits — they want honest ones.

Bottom Line

United States v. Felton is a reminder that when you rely on a confidential informant, you need to give the judge a full picture. Officers don’t need to overthink or sugarcoat — they just need to disclose everything relevant to credibility and corroborate actual criminal activity whenever possible.

In other words: If your case relies on an informant, treat transparency as officer safety — but for your case.