STATE OF LOUISIANA v. ANGELO WILLIAMS (2026)

Relator, the State of Louisiana, seeks review of the trial court's July 1, 2026 ruling granting a motion to suppress evidence filed by Defendant-Respondent, Angelo Williams. For the following reasons, we grant the writ application, reverse the trial court judgment, and remand this matter to the trial court for further proceedings.

On February 5, 2026, Defendant was charged by bill of information for possession of a controlled dangerous substance, to wit: fentanyl, in violation of La. R.S. 40:967(C)(4)(b). Defendant was arrested on December 9, 2025 pursuant to a November 6, 2025 alias capias issued in an unrelated criminal matter for failure to appear in court. A subsequent search of Defendant's person incident to the arrest resulted in the recovery of illegal substances.

On June 11, 2026, Defendant filed a motion to suppress the evidence, contending that the alias capias relied on in arresting Defendant had been recalled by the trial court on November 17, 2025. Defendant argued that because the warrant was invalid, the subsequent search of Defendant's person was invalid and unconstitutional. In support of his motion, Defendant introduced a November 17, 2025 trial court order in the unrelated criminal matter reflecting that Defendant had appeared in court in that matter and ordering that the alias capias be recalled.

At the motion to suppress hearings ¹ , Sergeant King Tao, a 29-year sergeant with the Orleans Parish Sheriff's Office and a member of the U.S. Marshall's Task Force, testified as to the circumstances surrounding Defendant's arrest. Sgt. Tao testified that, approximately one to two weeks prior to the arrest, another deputy with the records department verified and confirmed that an alias capias was issued and active for Defendant's arrest. The State also introduced into evidence a “Notice of Failure to Appear and Alias Capias” reflecting that on December 3, 2025, six days prior to Defendant's arrest, the Clerk's Office for the Criminal District Court for the Parish of Orleans issued the notice of alias capias—after the alias capias had been recalled.

Upon considering the evidence, the trial court found that the “deputies acted in good faith” in arresting Defendant based upon the records available to officers at that time and that the officers were not aware at the time of Defendant's arrest that the alias capias had been recalled. Nevertheless, the trial court found that Defendant should not be punished for the multiple administrative failures of multiple government agencies and granted Defendant's motion to suppress.

The United States Supreme Court and this Court have found that, when an arresting officer arrests a defendant pursuant to an invalid warrant but does so in good faith, the exclusionary rule is not applicable and the evidence recovered need not be suppressed. See Herring v. U.S., 555 U.S. 135, 129 S. Ct. 695, 172 L. Ed. 2d 496 (2009); U.S. v. Leon, 468 U.S. 897, 104 S. Ct. 3430, 82 L. Ed. 2d 677 (1984); and State v. Johnson, 2008-1551 (La. App. 4 Cir. 2/5/09), 6 So.3d 195, 196 (wherein this Court, in reversing the granting of a motion to suppress based on an invalid arrest warrant, considered that the “officer [ ] acted in good faith when he arrested [the defendant] based on the information available to him at the time.”). Moreover, the United States Supreme Court has specifically found that “a mistake made by a judicial employee could not give rise to exclusion” of evidence where the arresting officers acted in good faith. Herring, 555 U.S. 135, 142, 129 S. Ct. 695, 701, 172 L. Ed. 2d 496 (2009), quoting Arizona v. Evans, 514 U.S. 1, 14–15, 115 S. Ct. 1185, 131 L. Ed. 2d 34 (1995).

Under the facts of this case where the trial court made a factual finding that the arresting officers proceeded in good faith to arrest Defendant based on an issued alias capias with no evidence that the officers had been aware that the alias capias had been recalled, we find that suppression of the recovered evidence is not appropriate and that the trial court erred in granting Defendant's motion to suppress. Accordingly, we grant this writ application, reverse the trial court's judgment, and remand this matter to the trial court for further proceedings.

WRIT GRANTED; JUDGMENT REVERSED

FOOTNOTES

1.   The initial suppression hearing took place on June 12, 2026. The trial court left the suppression hearing open and a continuation of the hearing took place on July 1, 2025.

Judge Monique G. Morial