CA6: Driving from home to scene of drug deal is PC and nexus for the home

“To obtain a search warrant under the Fourth Amendment, the police must have “probable cause” that the ‘place’ they seek to search contains the ‘things’ they seek to seize. U.S. Const. amend. IV. Applying this test, we have repeatedly held that probable cause exists to search a residence for drug-related evidence when a drug dealer travels directly from that residence to the site of a drug deal. See, e.g., …. The facts of this case fit that profile: Just before his arrest, the police watched James Miller leave an apartment with a grocery bag, drive to a nearby parking lot, and sell drugs. The district court thus correctly held that probable cause supported a warrant to search the apartment. We affirm Miller’s conviction.” United States v. Miller, 2021 U.S. App. LEXIS 8719 (6th Cir. Mar. 23, 2021).