CA11: Mistake in apt number in SW wasn’t fatal flaw because of “rich detail” describing the apt door

The search warrant had the wrong apartment number, but the location of the apartment was described in “rich detail,” including that the door had numerous stickers. Therefore, defense counsel wasn’t ineffective for not challenging the search warrant. United States v. Gordon, 2018 U.S. App. LEXIS 1043 (11th Cir. Jan. 16, 2018):

Here, the warrant described the location in rich detail. It correctly named the apartment complex, noted the building was a two-story multi-dwelling building and the apartment was on the first floor, and described the apartment as having a green front door with “numerous stickers” on it. It also included the proper apartment number. It was, however, incorrect in one respect: it described the address as “2900 Perimeter Parkway, Apt. 205.” The apartment complex was bordered by both Perimeter Parkway and Huntington Drive, and the apartment address was actually 2900 Huntington Drive, Apartment 205. But this is far from a fatal flaw. The correct apartment was noted in every other respect and the searching officers executed the warrant on the correct apartment. The small misstep of including the wrong bordering street in the address is, in this case, inconsequential. See United States v. Figueroa, 720 F.2d 1239, 1243 n.5 (11th Cir. 1983). It could not serve as a basis to challenge the warrant.