D.Minn.: Failure to show nexus still saved by GFE because there’s always an inference

The affidavit for warrant here completely failed to link defendant’s residence to drugs. One fact was that he left there, met up with a confederate, and went to a drug deal. That wasn’t enough. Still, the good faith exception saves the search. The inference alone that drugs are usually kept at home is enough. United States v. Dejesus, 2023 U.S. Dist. LEXIS 174312 (D. Minn. Aug. 4, 2023):

Given that it is logical to infer that someone in possession of valuable contraband would store that contraband in a safe, accessible location such as his or her residence, based on all the facts and circumstances of this case, it was not “entirely unreasonable” to rely on the warrant providing probable cause to search the home for possible contraband he was storing at the White Bear Avenue Residence. For all of these reasons, the Court recommends denying the motion to suppress evidence seized at the White Bear Residence.

And, once again, the good faith exception nullifies the nexus requirement of the Fourth Amendment.

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