UNITED STATES OF AMERICA v. JAAVAID ALAN MCCARLEY-CONNIN - Articles

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UNITED STATES OF AMERICA v. JAAVAID ALAN MCCARLEY-CONNIN

Posted by: Azya Thornton on Aug 22, 2025

Court: 6th Circuit Court (Published Opinions)

Attorneys 1: ON BRIEF: Krysten E. Beech, FEDERAL PUBLIC DEFENDER’S OFFICE, Toledo, Ohio, for Appellant.

Attorneys 2: ON BRIEF: Joseph H. Walsh, UNITED STATES ATTORNEY’S OFFICE, Cleveland, Ohio, for Appellee.

Judge(s): MOORE and NALBANDIAN, Circuit Judges

Court Appealed: United States District Court for the Northern District of Ohio at Toledo

NALBANDIAN, Circuit Judge. Two suspicious packages, two weeks apart, passed through the Cleveland Postal Service distribution center in early 2021. United States postal inspectors flagged both for a possible connection to drug trafficking. After more research that added to their suspicion, inspectors called for a canine sniff of the packages. The dog, Ciga, alerted to both. Based on this evidence, a Postal Inspector applied for search warrants to open the packages and both revealed evidence of illicit activity. The investigation that followed led to the arrest and indictment of Jaavaid McCarley- Connin for his role in a drug-trafficking conspiracy. He moved to suppress the evidence from the package searches. He claimed he was entitled to an evidentiary hearing and extrinsic evidence to undermine Ciga’s reliability. The district court denied the motions, so McCarley- Connin pleaded guilty but reserved his right to challenge the trial court’s ruling on the suppression motion. Now, he presses on us the same theory that the district court denied below. First, he claims that Florida v. Harris, 568 U.S. 237 (2013) entitles him to an evidentiary hearing because he offered extrinsic evidence undermining Ciga’s reliability. And second, he claims that even without a hearing, Harris required the court to consider his extrinsic evidence; if he had, the court would have found the affidavit lacked probable cause. Because Harris does not reach as far as McCarley-Connin suggests, we AFFIRM the district court.

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