M.D.Pa.: Error in USPS tracking number of parcel in SW was a “mere technical error” when it was readily apparent they had right package

Error as to USPS tracking number in an anticipatory warrant wasn’t fatal and didn’t make the warrant not particular. All the other information was correct as to sender, recipient, description, and shipping location. This was a “mere technical error” that could be overlooked. “Indeed, the Search Warrant contained sufficient information for the executing officer (PI Corricelli) to identify the correct package and, having already executed the search warrant for the ‘4884 Parcel, there was no reasonable likelihood that the wrong item would be searched.” United States v. Santana, 2020 U.S. Dist. LEXIS 234104 (M.D. Pa. Dec. 14, 2020).

The affidavit for this search warrant on the totality shows a time frame, and isn’t general as to time. There are CIs who are both known and anonymous, and they were sufficiently corroborated. Finally, the corroboration showed nexus. State v. Jones, 2020-Ohio-6667, 2020 Ohio App. LEXIS 4523 (3d Dist. Dec. 14, 2020).*

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