The search warrant’s describing the dwelling as a single family dwelling when it was really two and defendant lived on the second floor didn’t make it overbroad. It did not appear to be a multi-unit dwelling and defendant answered the door they knocked at. The part defendant lived in was all that was searched. People v. Vandebogart, 2018 NY Slip Op 01214, 2018 N.Y. App. Div. LEXIS 1234 (3d Dept. Feb. 22, 2018).
The affidavit for the search warrant showed nexus: “The police officers observed Defendant leaving the residence, walking to meet the confidential informant after arranging to sell the C/I drugs, and then returning to the same Burlingame residence.” United States v. Wilson, 2018 U.S. Dist. LEXIS 30538 (W.D. Mich. Feb. 26, 2018).*