United States v. Holt

── United States v. Holt ── Court: Court of Appeals for the Tenth Circuit Date: April 24, 2026 Category: General Appellate Case: 25-5078 Document: 36-1 Date Filed: 04/24/2026 Page: 1 FILED United States Court of Appeals PUBLISH Tenth Circuit UNITED STATES COURT OF APPEALS April 24, 2026 Christopher M. Wolpert FOR THE TENTH CIRCUIT Clerk of Court _________________________________ UNITED STATES OF AMERICA, Plaintiff - Appellee, v. No. 25-5078 LEE HOLT, a/k/a Timothy Scott Holt, a/k/a Lee Scott Holt, Defendant - Appellant. _________________________________ Appeal from the United States District Court for the Northern District of Oklahoma (D.C. No. 4:24-CR-00050-JFH-1) _________________________________ Submitted on the briefs: * Julia L. O’Connell, Federal Public Defender, and Stephanie A. Baker, Assistant Federal Public Defender, Office of the Federal Public Defender, Tulsa, Oklahoma, for Defendant- Appellant. Clinton J. Johnson, United States Attorney, and Thomas E. Duncombe, Assistant United States Attorney, Office of the United States Attorney, Northern District of Oklahoma, Tulsa, Oklahoma, for Plaintiff-Appellee. _________________________________ Before TYMKOVICH, MURPHY, and MORITZ, Circuit Judges. _________________________________ After examining the briefs and appellate record, this panel has determined * unanimously to honor the parties’ request for a decision on the briefs without oral argument. See Fed. R. App. P. 34(f); 10th Cir. R. 34.1(G). The case is therefore submitted without oral argument.  Appellate Case: 25-5078 Document: 36-1 Date Filed: 04/24/2026 Page: 2 _________________________________ TYMKOVICH, Circuit Judge. _________________________________ Oklahoma law enforcement suspected Lee Holt of selling methamphetamine from his home. Officers obtained two warrants to search Holt’s home: one from a tribal court judge, because the home was in Indian Country, and the other from a state court judge, because officers believed the non-Indian status of Holt’s co- resident supported state jurisdiction. The tribal judge issued the warrant. The state judge also did—but only after the agent submitted a revised probable-cause affidavit. State and tribal officers executed the tribal search warrant and found firearms, ammunition, and drugs in Holt’s home. After the case was referred to federal officials, a federal jury convicted Holt of drug offenses and firearm offenses. The court sentenced him to fifteen years’ imprisonment. In the district court prior to trial, Holt moved to suppress the contraband found in his home as the fruit of an unlawful search. Applying the good-faith exception, the court denied the motion. Holt also moved to compel identification of the government’s confidential informant, who helped tie Holt to drug distribution. The court ultimately denied that motion finding that Holt failed to show identification would assist his trial defense. On appeal, Holt challenges both decisions by the district court. He contends the district court erred by denying the motion to suppress because officers could not rely in good faith on the tribal warrant because a state judge had contemporaneously 2  Appellate Case: 25-5078 Document: 36-1 Date Filed: 04/24/2026 Page: 3 rejected an i