CA5: SW for 320 CR 401 didn’t include 320A; telephonic warrant fails for lack of a record of what caused to issue

A search warrant for 320 CR 401 did not objectively include 320A CR 401, a different address and building 200 yards away with a separate electric meter, so summary judgment was improperly granted the police. In addition, a telephone warrant was used and Mississippi case law six years earlier said you couldn’t do that. There was no record of what was discussed in getting the warrant. Rogers v. Lee County, 2017 U.S. App. LEXIS 5747 (5th Cir. April 3, 2017) (see Treatise § 55.14 on telephone warrants).