The showing of nexus was thin, but not bare bones, and it was reasonable to infer that evidence of three robberies would be found where he was staying with his girlfriend. There clearly was probable cause to arrest him in that place. The question was whether there was also probable cause to search, and there was. United States v. Amos, 2018 U.S. Dist. LEXIS 73812 (E.D. Wis. May 2, 2018):
As the government indicates in its response, defendant does not dispute that the agents had probable cause to search the Lisbon residence to arrest him; rather, his claim is that the court should not have also issued a warrant for evidence of the robberies. It was not unreasonable for the agents to believe that evidence of the robberies would be found at the Lisbon residence. The agents knew that defendant had left some robbery evidence behind at his previous temporary residence in Sheboygan; it was not unreasonable for them to believe that they would find additional evidence at what appeared to be his new resting place in Milwaukee. As the government notes, there was no indication that defendant had some other, more permanent home where he would be more likely to stash his gun, money, or clothing, none of which had been recovered at the Sheboygan residence. See United States v. Anderson, 450 F.3d 294, 303 (7th Cir. 2006) (“Probable cause does not require direct evidence linking a crime to a particular place. Instead, issuing judges are entitled to draw reasonable inferences about where evidence is likely to be found given the nature of the evidence and the type of offense.”) (internal citations and quote marks omitted). “At a minimum, the affidavit was not clearly lacking in indicia of probable cause, but presented a close call. Once the magistrate judge made that call, it was objectively reasonable for the officers to rely on it.” United States v. Hodge, 246 F.3d 301, 309 (3d Cir. 2001).