W.D.Fla. & D.Md.: Nexus is established by a reasonable inference the object sought will be found

Nexus was shown for a search of defendant’s house for counterfeit money. The police had reports from CIs having bought counterfeit money from him at 10¢ on the dollar, and his house was surveilled, resulting in seeing him carrying a package to another currency drop with the CI, and the money was damp when the package was opened. That’s a reasonable enough inference for nexus to defendant’s house. In any event, the good faith exception applies. United States v. Losier, 2015 U.S. Dist. LEXIS 47080 (W.D. Fla. February 16, 2015):

Significantly, the last delivery of damp currency occurred just three days prior to the issuance of the search warrant; Defendant Losier left the residence in question and was followed by agents to the delivery point. A reasonable inference from these facts is that Defendant Losier had been manufacturing the counterfeit currency in the residence to be searched just prior to leaving that day. And a reasonable conclusion, based on the totality of the circumstances, is that evidence of the crimes of manufacturing and dealing in counterfeit U.S. currency would be found in the residence. See Joseph, 709 F.3d at 1099 (stating “[t]his circuit has stated that probable cause exists if facts within the magistrate [judge]’s knowledge and of which he had reasonably trustworthy information would warrant a man of reasonable caution in the belief that a crime was committed and that evidence is at the place to be searched”) (quotation and citation omitted). Accordingly, the Affidavit established probable cause to believe that evidence of the crimes would be found in the place to be searched.

“The physical surveillance and intercepted communications in the affidavit thus establish a nexus between N. Zakharyan and the contraband cigarette operation, and between the operation and his home.” United States v. Zakharyan, 2015 U.S. Dist. LEXIS 46580 (D.Md. April 9, 2015).*