M.D.Pa.: Despite appearance building was multi-unit, SW was still particular because it alleged he was in control

The search warrant was sufficiently particular despite there being more than one entrance to the building and the fact there were multiple electric boxes outside. Based on what the officers knew, it was either one or all under his control. United States v. Laury, 2019 U.S. Dist. LEXIS 180484 (M.D. Pa. Oct. 18, 2019):

These arguments, however, fail to demonstrate the investigating officers should have known that the Park Avenue Residence was a multiple unit structure. The fact that a residence has multiple entry ways and multiple occupants is not necessarily evidence that a structure is comprised of multiple units. See United States v. Roman-Polanco, No. 3:17-CR-78, 2019 U.S. Dist. LEXIS 60739, 2019 WL 1548899, at *14 (M.D. Pa. Apr. 9, 2019) (explaining that the existence of multiple doorways is not dispositive evidence that a structure contains multiple separate units). Moreover, in the affidavit of probable cause, Agent Noone specifically stated that in his professional experience, narcotics distributors often hide contraband in “secure locations within residences over which they exercise dominion and control” and “the residences of their confederates, paramours, and relatives, and their stash houses.” (Doc. 133-3, at 9). Thus, the search warrant is valid based on the information that officers disclosed and had a duty to disclose to the magistrate judge.

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