this case turns around whether or not the search warrant affidavit provided sufficient probable cause to search the residence that was associated with mr johnson it is our position that it did not did not and there were three problems with the warrant and i will address each of the three in turn three were first of all and foremost the law enforcement had no prior dealings with the cooperating informant in this case and so this court looks with greater skepticism  and to justify a search of a residence associated with with him and it's our position that in addition to this case being very important to mr johnson and approving of a search warrant based on unverified statements to the cooperate informants in this case they were husband and wife and mr coleman the original informant went through several iterations of of his story first refusing to talk  secondly saying that he was going to try and make a deal for his wife and thirdly claiming that mr johnson was one of his sources of supply for the heroin that that was found in his house he was caught red handed he had no choice but to say that yes this was his and he wanted to make sure that his wife was not charged his wife had the same goal for her part she was willing to point the finger at her husband and also mentioned mr johnson in an effort to keep herself out of criminal conduct the problem is that the police didn't take our law enforcement didn't take any steps to independently corroborate this as is usually done and it residence they were talking about was actually the same residence they didn't do any controlled purchases and they didn't do anything else to verify what these people said they didn't look at mr johnson to see if he was engaged in a suspect illegal activities all the information they had about mr johnson was that he was associated with the address that was actually owned or at least located on a couple of occasions and february so they didn't have any information at all about mr johnson's contemporaneous activities either in that building or outside that building they did have a prior conviction from two thousand and two for mr johnson and that conviction however was listed without saying what exactly it was beyond that it was a distribution of drugs but the drugs involved in that earlier conviction were cocaine and not heroin mr johnson had no history of dealing in care one of using it or possessing it so they had very little information about mr johnson and what his contemporaneous activities were and no information suggesting that there was illegal or corroborating the assertion by the informants that there was illegal activity going on in this particular condominium and they couldn't even use the general excuse that this was a drug trafficking area because the place where the condo was located in greektown was not such an area so there was very bare bones for operation any of the information that was provided by these informants informants on the other hand in addition to their reasons for lying or providing information that misdirected the police and in somebody else's direction they also at least with respect to mr coleman  was a long term heroin addict and in fact he had told the agents at the time that he was about to be sick meaning that he had had not had his heroin dose and he was about to start going through withdrawal symptoms and it's not clear in the record or in the affidavit what effect if any this had on the timing or the provision of information by this informant in fact there is some indication that was not provided to the district court or to the magistrate well not to the magistrate and right that mr coleman was offered an opportunity to confirm what he had said and corroborate his information by making a recorded call to mr johnson but he refused to do that because he said he was feeling tired which could also mean that he was indeed experiencing the beginning to or in the middle of experiencing withdrawal symptoms from paranoia the fact that he was can released for imprisonment does not say one way or another whether he was being treated for his symptoms and to what extent he was experiencing and while this court has said there's no per se rule that a confession or statements are involuntary or otherwise incredible because someone is a drug user it's an indication that should have been addressed with respect to this particular informant and lends to the the likely credibility and right unreliability of this informant which would suggest the need for further or additional law enforcement corroboration of what the informant said so going back to mr johnson a law enforcement knew at that time that his actual residence was in in the park and  information was not provided either they knew that he was associated with this address or claim that he was put provided no information either in the affidavit or otherwise to indicate when or how or for how long or in what context he was associated with that particular address so for all of those reasons there was insufficient probable cause on the face of the warrant in order to justify the search of this particular i didn't destroy coleman given actually the condo number i mean there was some specificity once he did give a condo number he wasn't able to give the address the agents found the address but he did give the condo a number he did not however provide any information about where in the residence the drugs might be held and there was no corroboration that that was the particular unit th johnson was this is pretty specific about the amounts that he dealt with them with the defendant did he not yes he was specific about the amounts that that he was purchasing and selling which of course he would be and he could easily substitute mr johnson's name for anybody other anybody else's name as well there was nothing to corroborate that he was actually purchasing those two hundred grams from mr johnson as opposed to any of his other sources prior to the search warrant in the defendant's apartment the information provided by the informant was timely it was supported by his firsthand observations of drugs in the defendant's attorney and it was detailed it contained information about the particular place where the heroin transaction occurred including a condo number he was showing a photograph of the condo building and positively identified it for the agents it was detailed in terms of quantity in price both on a particular day two days prior as well as a course of dealing with the defendant and it was detailed in terms of the date on which that last transaction occurred it also was corroborated in material respects that agents separately interviewed the informant's wife who provided similar information about the defendant's course of dealing with her husband it was corroborated in terms of the defendant's link to the residence identified by the informant and it was c rated by the agencies or of heroin from the informants residence that morning which indicated it was substantially similar in quantity to the amount that he had obtained from the defendant just two days prior for all of those reasons you're on as i think the framing of this question is a little bit cited it is certainly true that mr solomon the informant provided detailed information about his own activities but he did not provide sufficiently detailed information about mr johnson no nor was there sufficient information about mr johnson independently it obtained by law enforcement either about him or his residence that would justify the search and again opening the floor based on s