CA6: No direct evidence of nexus required where a drug trafficker’s home is ID’d and he operates from there

“In fact, we have even gone so far to determine the existence of ‘a nexus between a defendant’s residence and illegal drug activity with no facts indicating that the defendant was dealing drugs from his residence.’ McCoy, 905 F.3d at 418 (emphasis added). Instead, we determined that a ‘defendant’s record of past drug convictions coupled with recent, reliable evidence of drug activity’ is sufficient to establish the nexus. Id.; see also United States v. Miggins, 302 F.3d 384, 393 (6th Cir. 2002) (finding probable cause existed to support search of defendant’s residence based on affidavit’s outlining of defendant’s prior cocaine-related convictions coupled with officers’ same-day observations of him signing for a package containing a large amount of cocaine delivered at someone else’s residence).” United States v. Sumlin, 2020 U.S. App. LEXIS 12744 (6th Cir. Apr. 21, 2020).

“Jenkins’s home. And Chadwell admitted at the traffic stop that he had obtained his pills from Jenkins and that he had just driven from Jenkins’s residence. Thus, the evidence here goes beyond the legally permissible inference that drug traffickers generally store drugs in their homes. The issuing judge had more than a ‘substantial basis’ for finding the affidavit established probable cause.” United States v. Jenkins, 2020 U.S. Dist. LEXIS 69551 (E.D. Ky. Mar. 11, 2020), adopted, 2020 U.S. Dist. LEXIS 69247 (E.D. Ky. Apr. 21, 2020).*