D.Nev.: There is no co-conspirator standing

Defendant was charged as a co-conspirator in a drug conspiracy involving a warehouse. He makes no effort to show his individual standing, and being a co-conspirator isn’t enough. United States v. Galecki, 2016 U.S. Dist. LEXIS 185667 (D. Nev. Sept. 19, 2016) (see Treatise § 4.18 n.22).

“To be sure, the Affidavit could have been more explicit about the link to John Avenue. But, as indicated, the Affidavit need not be a model of perfection to pass constitutional muster. The Affidavit recounts an extensive investigation linking the defendants to cocaine distribution. The issuing judge was entitled to infer from the Affidavit that contraband would be found at the John Avenue residence, a location that was frequented by Enixae and the other defendants. [¶] Even if the search warrant were not supported by probable cause, this would not end the inquiry. Deterrence “is not achieved through the suppression of evidence obtained by ‘an officer acting with objective good faith,'” pursuant to a search warrant issued by a judicial officer.” This was all in good faith. United States v. Villapando, 2017 U.S. Dist. LEXIS 51698 (D. Md. April 5, 2017).*

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