The fact a package with drugs is coming to a particular address is enough to issue an anticipatory warrant for that address. A prior history of that address and drugs isn’t required. When the triggering condition is taking the package inside, and the package was left at the door, returning the package back outside with “return to sender” written on it doesn’t nullify the probable cause. United States v. Brown, 2017 U.S. Dist. LEXIS 120791 (W.D. Mo. July 21, 2017), adopted, 2017 U.S. Dist. LEXIS 120499 (W.D. Mo. Aug. 1, 2017):
Defendant additionally argues that when the Parcel was returned outside the front door with “return to sender” written on the package, the Parcel was rejected by the occupants of the residence. As the Court has already addressed, the triggering event occurred when Defendant carried the Parcel into the residence. Nothing within the search warrant indicated that execution was conditioned on the Parcel remaining within the residence. Once the triggering event occurred, execution of the Anticipatory Search Warrant was authorized. See United States v. Becerra, 97 F.3d 669, 671 (2d Cir. 1996) (“[A]n anticipatory warrant whose perfection requires no more than the delivery of a package to, or in the presence of, the suspect, is not invalidated because the parcel is taken off the premises after delivery.”) See also United States v. Jackson, 55 F.3d 1219, 1224 (6th Cir. 1995) (“We conclude that once the package was taken inside the Bardwell house, probable cause existed to search the premises not only for the contraband itself, but also for other evidence of drug trafficking.”).