CA1: Nexus is whether evidence will be found in the place searched, not whether a crime occurred there

“First, Joubert argues that a nexus is lacking because the affidavit contains no allegations that he committed any offenses at the location being searched. But Joubert misidentifies the relevant inquiry. The question is whether evidence of the crime is likely to be found in the specific place being searched, not whether the crime occurred there. See Zurcher v. Stanford Daily, 436 U.S. 547, 556-57 (1978); … see also United States v. Kapordelis, 569 F.3d 1291, 1310 (11th Cir. 2009) (‘There need not be an allegation that the illegal activity occurred at the location to be searched, for example the home’). As we explain below in rejecting Joubert’s third argument, there was indeed such a likelihood.” United States v. Joubert, 2015 U.S. App. LEXIS 2127 (1st Cir. February 11, 2015).