Photographs of the interior of defendant’s house taken before the search warrant issued are suppressed. They did not have any effect on the issuance of the warrant, however. United States v. Carey, 2020 U.S. Dist. LEXIS 190963 (M.D. Pa. Oct. 15, 2020).
The affidavit for the search warrant here readily showed probable cause that defendant was involved in drug dealing, but it fell short in showing any nexus to his house. Outbuildings on the property, yes, but house, no. There is no blanket rule attributing officer experience to make nexus, and here the only evidence was an outbuilding. State v. Nelson, 307 Ore. App. 226 (Oct. 14, 2020).