D.Mass.: SW for house permitted search of a hiding place in the outside wall

The defendant had a “hide,” a hiding place outside his house in the wall. The court finds the hide was withing the scope of the search warrant not and did not require a separate search warrant.
“I find that the hide was within the residence for which the warrant authorized the search. The fact that one needed to exit the residence to access the hide does not change the fact that the hide was located within the four walls of the residence. ‘Affidavit for search warrants must be tested and interpreted in a common sense and realistic fashion,’ United States v. Ventresca 380 U.S. 102, 85 S. Ct. 741, 13 L. Ed. 2d 684 (1965), and a ‘hyper-technical reading should be avoided.’ United States v. Bonner 808 F.2d 864, 868 (1st Cir. 1986). The warrant authorized the search of the house, which includes anything within the four walls.” United States v. Donald, 2019 U.S. Dist. LEXIS 86688 (D. Mass. May 23, 2019).