CA6: Nexus is PC for the place, not necessarily for a person in the place

Probable cause is a connection to a place to be searched, not necessarily to a person to be searched for in the place. That’s nexus. Here there was nexus. United States v. Adams, 2016 U.S. App. LEXIS 12793 (6th Cir. July 5, 2016):

To the extent defendant suggests the affidavit was insufficient to connect him to the conspiracy, he misunderstands the nexus requirement. A magistrate need not find probable cause that a particular person is likely involved in illicit activities; only that a particular place is likely to yield contraband. Search warrants “are not directed at persons; they authorize the search of ‘places’ and the seizure of ‘things,’ and as a constitutional matter they need not even name the person from whom the things will be seized.” Zurcher v. Stanford Daily, 436 U.S. 547, 555, 98 S. Ct. 1970, 56 L. Ed. 2d 525 (1978) (citation and alteration omitted). “The critical element in a reasonable search is not that the owner of the property is suspected of a crime but that there is reasonable cause to believe that the specific ‘things’ to be searched for and seized are located on the property to which entry is sought.” Id. at 556; see also United States v. Pinson, 321 F.3d 558, 564-65 (6th Cir. 2003). Here, the affidavit more than adequately demonstrated the “nexus between the place to be searched” (the Ten Mile Road location) and “the evidence sought” (proof of a drug conspiracy). Carpenter, 360 F.3d at 594.