NY2: Date typo in drug field test report after search wasn’t material

Defendant’s motion to suppress was properly denied by the trial court. Defendant’s reliance on when a field test of the product of the search showed only a typographical error as to the date it was done and doesn’t undermine the search. People v. Guichard, 2021 NY Slip Op 04030, 2021 N.Y. App. Div. LEXIS 4118 (2d Dept. June 23, 2021).

There was probable cause shown in the face of the papers for the search warrant in this murder case. People v. Morel, 2021 NY Slip Op 04032, 2021 N.Y. App. Div. LEXIS 4150 (2d Dept. June 23, 2021).*

The trial court properly found that the search warrant did not contain any misleading information because the detective’s references in the affidavit to information gleaned by “officers,” “they,” and “her sister” created a reasonable inference that the information was not obtained by the detective directly and a witness was listed on the warrant. State v. Edwards, 2021 Tenn. Crim. App. LEXIS 281 (June 22, 2021).*