CA6: Nexus shown to search def’s house for evidence of his drug deals

Defendant’s drug dealing connections were sufficient to establish nexus to his house. Drug dealers cannot immunize their activities by doing drug deals in parking lots. In any event, the good faith exception applies. United States v. Jenkins, 2018 U.S. App. LEXIS 20518 (6th Cir. July 24, 2018):

Drug dealers cannot immunize themselves from search of a residence used to store their supply simply by ensuring that all drug deals take place in parking lots. Indeed, in hypothesizing what would constitute a sufficient nexus between a residence and drug activity, we postulated in Brown that “[a] more direct connection …, such as surveillance indicating that [a defendant] had used the car [registered to his home] to transport heroin from his home to [a co-conspirator’s] on the day in question” would have be sufficient to meet the nexus requirement. 828 F.3d at 383. Here, the affidavit stated that investigators observed Howell leave Dragonfly in a car registered to Reynolds-the registered tenant of Dragonfly-sell drugs, and then immediately return to Dragonfly. Taken together with the inference “that drug traffickers use their homes to store drugs and otherwise further their drug trafficking,” Williams, 544 F.3d at 687, and the additional specific facts articulated in the affidavit, there was probable cause to support issuance of the Dragonfly warrant.