IRS agents’ search of the home office behind defendant’s home was reasonable and did not violate the Fourth Amendment where the search warrant described defendant’s primary residence but the office carried a different address. It was reasonable to believe the address listed on defendant’s company documents was in fact the address of the office. Moreover, no signs or markings indicated that the home office carried a separate address, and both structures were similar in appearance, were contained on a singular rectangular lot within the same fenced area, appeared to be connected by the same utility wires, and were connected by a sidewalk. United States v. Scully, 2020 U.S. App. LEXIS 6808 (5th Cir. Mar. 4, 2020).
Defendant’s traffic stop was reasonable suspicion for a detention and the smell of marijuana justified continuing it. United States v. Conley, 2020 U.S. Dist. LEXIS 37016 (W.D. La. Feb. 5, 2020),* adopted, 2020 U.S. Dist. LEXIS 36015 (W.D. La. Mar. 2, 2020).*