United States v. Leron Liggins -Eastern District of Michigan at Detroit
Split Score
What is a Split Score?
This score (0-100) indicates how likely this case is to be reviewed by the Supreme Court based on:
Case Summary
Disposition
Affirmed
The Sixth Circuit affirmed the district court’s denial of Leron Liggins’s motion to suppress evidence obtained after an improperly authorized Arizona wiretap. The court held that, regardless of which interpretation of the term “aggrieved person” under 18 U.S.C. § 2510(11) prevails in the current circuit split, Liggins lacked statutory standing because he neither participated in nor was targeted by the intercepted calls at issue.
Circuit Split Identified
Legal Issue
Whether the term “aggrieved person” in 18 U.S.C. § 2510(11) extends beyond Fourth-Amendment-style standing to include individuals who are merely investigative ‘targets’ of a wiretap application.
Circuit Positions
Historical approach: § 2510(11) incorporates Fourth Amendment standing; only participants in the call or owners/possessors of the tapped premises or device are ‘aggrieved persons.’
Plain-text approach: ‘Aggrieved person’ also covers investigative targets named in the wiretap application or order, even if they did not participate in the intercepted calls or own the tapped line.
Sixth Circuit (this opinion): Declines to choose between the two approaches; holds that defendant lacks standing under either test.
Conflict Summary
Some circuits limit § 2510(11) to traditional Fourth Amendment standing—only persons who were parties to the intercepted communication or whose property/phones were tapped may move to suppress. Other circuits read the statute’s plain text to grant standing to any person against whom the interception was ‘directed,’ including named investigative targets even if they did not participate in or own the tapped line.