Matthew Joseph Sheehan was stopped by Michigan State Police in June 2023 after officers tracked his cell phone to La Crosse, Wisconsin, and nearby Brownsville, Minnesota. Detective Cole Hodge believed Sheehan had just obtained a new shipment of drugs and instructed officers to stop him based on reasonable suspicion.
A canine unit alerted to the presence of drugs in Sheehan’s vehicle, leading to a search that recovered roughly a pound of methamphetamine from a safe in the trunk. Police subsequently obtained a search warrant for Sheehan’s residence, where they found more illicit substances, large amounts of currency, and drug trafficking tools.
Sheehan moved to suppress the evidence from his car, arguing the stop was unconstitutional, and contended that the evidence from his home was the fruit of a poisonous tree. The district court denied the motion, concluding the officers had reasonable suspicion, and Sheehan later pleaded guilty to possessing methamphetamine with intent to distribute.
The Sixth Circuit reviewed the district court’s determination de novo, noting that reasonable suspicion requires only a moderate chance of finding evidence of wrongdoing based on the totality of the circumstances. The court agreed with the lower court that the stop was justified.
Police had gathered significant information over several months, including tips from four confidential informants who identified Sheehan as trafficking drugs from south of the Michigan border. Cell-site data corroborated these tips by showing Sheehan made monthly trips to the La Crosse area between March 2022 and November 2022.
The court rejected Sheehan’s arguments that the informants were unreliable due to pending charges or prior convictions, noting that police independently corroborated key information through a surveilled controlled buy and cell-site data. The court also found the information was not stale, as Sheehan’s drug trafficking was an ongoing crime.
Because the court held that reasonable suspicion supported the initial stop, Sheehan’s challenge to the residential search warrant also failed. The Sixth Circuit affirmed the district court’s denial of the motion to suppress and the resulting conviction.