M.D.Tenn.: SW affidavit didn’t sufficiently show nexus, but not so lacking that GFE didn’t apply

The affidavit for the search warrant here failed to show nexus to defendant’s house under Sixth Circuit precedent. It was sufficient, however, for the good faith exception to apply because the affidavit was not so lacking in information that reliance on it was unreasonable. United States v. Anderson, 2018 U.S. Dist. LEXIS 81751 (M.D. Tenn. May 15, 2018).*

“[A]n individual’s presence in a high crime area simply does not establish reasonable suspicion. The other incidental facts present here—including Defendant speaking to the runners and an unknown male—are innocuous and not demonstrably linked to any criminal activity on the part of Defendant.” United States v. Williams, 2018 U.S. Dist. LEXIS 80483 (D. S.C. May 14, 2018).*

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