TN: One reference to address as “Drive” not “Street” hardly makes the SW without PC or otherwise invalidate it

“The address is shown as ‘106 Melwood Street’ nine times in the affidavit and one time as ‘106 Melwood Drive.’ Based on the totality of the information contained in the affidavit, we determine that the use of the word ‘drive’ was an innocent mistake that is ‘insufficient to invalidate the search warrant.’” State v. Martin, 2019 Tenn. Crim. App. LEXIS 282 (Apr. 30, 2019).

Michigan adheres to its prior cases that a person convicted can reject probation and take incarceration if he objects to the search condition. Accepting probation is a waiver. People v. Bensch, 2019 Mich. App. LEXIS 1496 (Apr. 30, 2019).

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