CA11: Multiple addresses for large rural property didn’t make SW for one address lack particularity

The search warrant for rural property described a 26 acre “lot” which the officers reasonably believed was all covered by one address. It turned out that it wasn’t, and there was another address for it all, too. Still, the warrant was sufficiently particular and it described multiple buildings on the property. United States v. Martinez-Martinez, 2019 U.S. App. LEXIS 19454 (11th Cir. June 28, 2019):

The difference between Garrison and the present facts is that the record here establishes that the warrant did not mistakenly include a “wrong” residence. Detective Rodriguez testified that he intended all along to search the “multiple trailers and multiple campers” on the property. Although it turned out that the mailing address of Martinez’s grey mobile home was 135 Milton Rahn Road, not 275 Milton Rahn Road, Rodriguez reasonably believed based on his investigation that 275 Milton Rahn Road was the address for the entire 26 acres, including both Rangel’s and Ramirez’s personal homes. For example, a co-worker of Montoya’s told Rodriguez that Rangel lived on a large property referred to as a farm, and county deputies told him about shots-fired complaints from neighbors that referred to the entire multi-trailer property as 275 Milton Rahn Road. Moreover, the detailed description of the property in the affidavit and warrant identifies Rangel only as the owner of the entire property and describes multiple dwellings without identifying one in particular as Rangel’s personal home. Therefore, even if it were unclear from the address Rodriguez gave that he intended to search each of the dwellings on the property, including the mobile home actually at 135 Milton Rahn Road, his physical description clarified that his declaration applied to each dwelling. See Burke, 784 F.2d at 1092 (“The search warrant contained a detailed physical description of the building, minimizing the possibility that an apartment in any building other than the correct one would be searched.”). In light of the “due weight” we give to the judgment of “resident judges and local law enforcement officers,” Jiminez, 224 F.3d at 1248, we do not find the address ambiguities here to be fatal to the probable cause determination of the local magistrate.