S.D.Ohio: Among eight 4A issues, none prevails; failure to provide inventory at the time of search is ministerial and requires a showing of prejudice

Defendant raised almost every conceivable Fourth Amendment and Rule 41 issue he could, and the district court rejects them all: (1) “The information in the affidavit is insufficient to support a finding of probable cause as to the crimes listed in the warrant,” but it does. (2) “Probable cause cannot be based on wholly conclusory statements,” but they’re not. (3) “Probable cause cannot be based on an informant without corroboration,” but enough detail was to make it reliable enough. (4) “The affidavit and addendum to the search warrant contain false statements and omissions,” particularly omission of the CI’s criminal history, but that’s not determinative of much at all because most of them are assumed to be so. (5) “There is an insufficient nexus between the place searched and the evidence sought,” but there’s not. (6) The search warrant is overly broad,” but it is particular enough. (7) “Defendant was not provided a copy of the warrant at the time of the search,” but that’s a Rule 41 provision that requires a showing of prejudice, and none is shown or even suggested. (8) “Defendant also argues that the warrant is invalid, in part, because it relies on stale information,” but it’s not stale. United States v. Draper, 2019 U.S. Dist. LEXIS 205813 (S.D. Ohio Nov. 27, 2019).