N.D.Ohio: SW was defective as to second address for no showing of PC, but there really was PC, so GFE applies

Probable cause in a search warrant affidavit as to one address was not probable cause as to another. Yet, there was, in fact, separate unstated probable cause as to the second address. The officers reasonably relied on the search warrant for the second address so the good faith exception applies to the second address because there was probable cause. United States v. Humphries, 2020 U.S. Dist. LEXIS 130077 (N.D. Ohio July 23, 2020):

In the instant case, the search warrant affidavit tends to show that Defendant Humphries was involved in a continuous-and-ongoing drug trafficking business while he was staying at the Rockford address. Evidence of this business justified the probable cause finding for the search of the Fuller house, which Humphries does not challenge. And following McCoy, evidence of Defendant’s continual-and-ongoing drug trafficking operations is enough to find that the officers reasonably believed there was probable cause to search the Rockford address.

In sum, the Court concludes that the law enforcement officers in this case acted reasonably in relying on the faulty warrant. The good-faith exception to the exclusionary rule saves the evidence recovered in the search of the Rockford address. Likewise, any statements Humphries made while under arrest, and after he was given Miranda warnings, will not be suppressed.