NEW ORLEANS, LA – The U.S. Court of Appeals for the Fifth Circuit has affirmed the conviction of Miguel Rafael Rayos, Jr., for possessing a controlled substance with intent to distribute following the drug-related death of his roommate.
Rayos challenged the denial of his motion to suppress evidence, arguing that the search warrant was not supported by probable cause. The court, in an unpublished opinion issued Sept. 5, 2025 (No. 24-10993), applied its standard two-step inquiry: first determining whether the good-faith exception to the exclusionary rule applied, and then reviewing probable cause if necessary.
The panel found that the good-faith exception applied, noting that the affidavit supporting the warrant contained sufficient facts and circumstances to allow a magistrate to reasonably infer that illegal drug use contributed to the death and that evidence would likely be found in Rayos’s residence or vehicles. The court rejected Rayos’s claim that the affidavit was a “bare bones” filing with only conclusory statements.
Because a reasonably well-trained officer would have had no reason to believe the warrant was invalid, the Fifth Circuit held that the district court did not err in denying the motion to suppress. As a result, Rayos’s conviction was upheld.
