M.D.Pa.: Typo in SW address overlooked under GFE

Typographical error in the search warrant (648 South 21st Street rather than 748 South 21st Street) would be overlooked under the good faith exception where the correct property was searched. United States v. Carey, 2019 U.S. Dist. LEXIS 74140 (M.D. Pa. May 2, 2019).

Defendant’s car was left parked at a gas station with engine running, the radio too loud, and unattended. The officer waited, looked in, then waited for defendant to come back. “In this case, the initial stop was reasonable because Officer Huckaby had a particularized and objective basis for suspecting a traffic violation had occurred when he heard loud music coming from Hall’s vehicle and observed that the vehicle was idling and unattended, both of which are traffic violations under Louisiana law. Further, once he smelled the marijuana coming from the vehicle and observed the bag of marijuana inside the vehicle, Officer Huckaby had additional reason to suspect criminal activity, making it reasonable to extend the stop. Accordingly, the traffic stop did not violate Hall’s Fourth Amendment rights.” United States v. Hall, 2019 U.S. Dist. LEXIS 73522 (W.D. La. Apr. 15, 1, 2019),* adopted, 2019 U.S. Dist. LEXIS 72936 (W.D. La., Apr. 30, 2019).*

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