UNITED STATES OF AMERICA v. LERON LIGGINS - Articles

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UNITED STATES OF AMERICA v. LERON LIGGINS

Posted by: Azya Thornton on Feb 18, 2026

Court: 6th Circuit Court (Published Opinions)

Attorneys 1: ARGUED: Wade G. Fink, WADE FINK LAW, P.C., Birmingham, Michigan, for Appellant.

Attorneys 2: ARGUED: Andrea Hutting, UNITED STATES ATTORNEY’S OFFICE, Detroit, Michigan, for Appellee.

Attorneys 3: ON BRIEF: Wade G. Fink, WADE FINK LAW, P.C., Birmingham, Michigan, for Appellant.

Attorneys 4: ON BRIEF: Andrea Hutting, UNITED STATES ATTORNEY’S OFFICE, Detroit, Michigan, for Appellee.

Judge(s): WHITE, STRANCH, and MURPHY, Circuit Judges

Court Appealed: United States District Court for the Eastern District of Michigan at Detroit

MURPHY, Circuit Judge. The police learned of Leron Liggins’s drug distribution after intercepting his coconspirator’s calls. Liggins moved to suppress the evidence derived from these calls based on a defect in the underlying wiretap application. But the federal wiretap laws allow only an “aggrieved person” to file such a motion. They define “aggrieved person” as “a person who was a party to any intercepted wire, oral, or electronic communication or a person against whom the interception was directed[.]” 18 U.S.C. § 2510(11). Courts disagree over this definition’s scope. Some read it to adopt the Fourth Amendment’s standing rules, which grant standing to those who participated in an intercepted call or who owned the property from which the call occurred. Others interpret it to reach the “targets” of a wiretap application too. Liggins asks us to adopt the broader view. At day’s end, though, we need not choose between the two approaches because Liggins would not qualify as an “aggrieved person” either way. He did not participate in the intercepted calls, the calls did not use his cellphone or occur at his home, the wiretap application did not identify Liggins as a “target” of the investigation, and no evidence suggests that he was otherwise an unnamed target. We thus affirm.

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