GA: Affidavit as a whole made nexus with clear inference sought after evidence would be found

The affidavit for the search warrant as a whole made a clear inference that the evidence sought would be in the defendant’s house. The rule adopted by the court of appeals is too broad, but the decision is still affirmed. Taylor v. State, 2018 Ga. LEXIS 73 (Feb. 5, 2018), aff’g but limiting Taylor v. State, 338 Ga. App. 804, 792 S.E.2d 101 (2016).

Defendants argued the FBI falsely reported their conversations with the officers but provided no evidence. The government put forth the 302s showing the contrary. Probable cause was shown. United States v. Gulley, 2018 U.S. Dist. LEXIS 18580 (N.D. Ohio Feb. 5, 2018).*

The officers provided a 61 page affidavit for the search warrant, and the defense claimed four omissions. They don’t undermine the showing of probable cause because they aren’t material. United States v. Pearl, 2018 U.S. Dist. LEXIS 18581 (N.D. Ohio Feb. 5, 2018).*