CA3: Doing drug deals from the car parked behind the house was nexus

“Walker argues there was no evidence supporting the third Burton premise. We disagree, as several of the ‘factors that help establish the required nexus between a defendant’s drug-dealing activities and his home’ are present in this case. … Walker conducted the drug transactions in a car parked in the driveway behind 6735 Woodstock, ‘rendering his home a more likely repository of his drug-related paraphernalia.’ … He was seen leaving the house immediately before selling drugs to the informant, supporting the inference that the drugs were being stored there. Finally, the affidavit provides that Weaver, an officer with substantial experience and specialized training in narcotics investigations, believed that the residence was being used for the storage and distribution of drugs.” United States v. Walker, 2019 U.S. App. LEXIS 18142 (3d Cir. June 17, 2019).

After defendant’s traffic stop, a search of the car’s interior was justified by his probation search waiver. United States v. Griffith, 2019 U.S. Dist. LEXIS 99686 (W.D. Mo. June 14, 2019).*

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