Henry H. Howe v. Steven Gilpin, et al.
Whether complete omission from an arrest warrant of a primary confidential informant's multiple prior Rule 609 [F.R.Evid.] "dishonesty and false statement" convictions actually known to the law enforcement warrant affiant – convictions for Theft False Representation, Theft By Swindle, Bigamy, "Theft More Than $35,000", Aggravated Forgery, and Check Forgery – is an omission which causes the warrant to be invalid if the warrant-issuing judge's probable cause determination was based on an affidavit with the omitted information exhibiting reckless disregard for the truth on the part of the law enforcement affiant.
Whether a law enforcement arrest warrant affiant's actual knowledge of a primary confidential informant's self-reported multiple prior Rule 609 [F.R.Evid.] "dishonesty and false statement" convictions creates a duty for that law enforcement warrant affiant to conduct further background investigation – at least including a check of the confidential informant's criminal history -- before presenting a warrant affidavit to a prospective warrant-issuing judge or magistrate.
Whether complete omission from an arrest warrant of a primary confidential informant's multiple prior Rule 609 [F.R.Evid.] 'dishonesty and false statement' convictions actually known to the law enforcement warrant affiant is an omission which causes the warrant to be invalid