As to nexus, it is reasonable to infer that the proceeds of a robbery are kept at the home of the robber. Also, “The affidavits need not prove that the belief that contraband or evidence of a crime will be found is ‘more likely true than false.’ Texas v. Brown, …. Instead, the search-warrant affidavits must show only a ‘fair probability’ that evidence of criminal conduct will be found. Illinois v. Gates, …. The affidavits for XXX39 and XXX45 Arlington met this standard.” The affidavits for the two search warrants here show nexus to the crime under investigation. United States v. Abbott, 2017 U.S. Dist. LEXIS 47500 (E.D. Mich. March 30, 2017) (see Treatise §§ 6.02 n.15, 56.03 & 56.14):
Moreover, police officers may fairly infer that participants in robberies will store stolen currency or firearms in their house. United States v. Jackson, 756 F.2d 703, 705 (9th Cir. 1985) (currency); United States v. Jones, 994 F. 2d 1051, 1056, 28 V.I. 375 (3rd Cir. 1993) (firearms). An officer may draw reasonable inferences about where evidence may be found based on the nature of the crime and type of offense committed. United States v. Williams, 544 F.3d 683, 686 (6th Cir. 2008). At a minimum, once police established a fair probability that Abbott participated in the robberies and that Abbott resided at the Arlington addresses, they had probable cause to search the residences for the stolen money, other tools and equipment used during the robbery, and clothing worn during the robberies. In sum, the affidavits established a sufficient nexus between Abbott, the alleged criminal activity, and the locations searched.