CT: Error in time on issuance of SW a “mere technicality” that can be overcome by state

Incorrect time of issuance on the search warrant was a “mere technicality” and a scrivener’s error that could be overlooked by the state proving the correct time. State v. Thompson, 307 Conn. 567, 57 A.3d 323 (2012); State v. Jevarjian, 307 Conn. 559, 58 A.3d 243 (2012) (Also, parking an RV at the house of another did not give one standing to contest the search of the entire house as an overnight guest. It presented a moot question on the RV which still supported the guilty plea.):

Turning first to the defendant’s claim that the trial court improperly relied on parol evidence to determine whether a scrivener’s error was made, we previously have observed that, “although probable cause must be determined from the four corners of the warrant, we are not confined to the four corners of the warrant in determining whether the affidavit in support of probable cause has been validly executed.” State v. Colon, supra, 230 Conn. 34. Mere technical defects are likewise insufficient to invalidate an otherwise valid search warrant. See, e.g., State v. Browne, 291 Conn. 720, 743-44, 970 A.2d 81 (2009). Accordingly, we do not agree with the defendant that the trial court’s reliance on parol evidence to determine the timing of the warrant’s execution was improper.