This investigation into a stolen car ring operated from a home garage showed nexus to the house, too. “The affidavit by Officer Chappell is clear and thorough and reflects months of information gathering. The affidavit explains the nexus between the focal point of the investigation — the allegations of a stolen car ring being operated out of the garage — and the request to search the house. First, the affidavit details the repeated visits by persons of interest and the contents of the trash-pulls. Second, the affidavit contemplates that indicia of the conspiracy — documents, papers, books, records, currency counters, and so on — would be located in the house, and the search warrant details these indicia specifically.” In addition, listing firearms didn’t make the search warrant overbroad. United States v. Peterson, 2019 U.S. Dist. LEXIS 1833 (S.D. Ohio Jan. 4, 2019).
Slight inconsistencies in the testimony of two officers about how the stop occurred didn’t so undermine their testimony that they were incredible and couldn’t be believed. United States v. Flippo, 2019 U.S. App. LEXIS 376 (11th Cir. Jan. 7, 2019).*