OR: Venn diagram of PC to a place or thing (nexus)

State v. Turay, 313 Ore. App. 45, 53, 2021 Ore. App. LEXIS 941 (July 8, 2021):

One circle is the specific crime of investigation. There must be facts that support a specific crime, not just generalized concerns of criminal activity. The second circle is the location to be searched. And, the third circle is the evidence of the specific crime of investigation that is expected to be found in the location searched. Where those three Venn circles overlap is the nexus—the point at which constitutional probable cause exists. The standard is one of probability, not certainty. Anspach, 298 Ore. at 380-81.

There was probable cause here as to defendant’s cell phone.