W.D.Wash.: “[i]n the case of drug dealers, evidence is likely to be found where the dealers live.”

The search under the search warrant in this case is not suppressed. While there was a traffic stop that could not be justified, it is excised from the affidavit for the search warrant, and the remainder still shows probable cause. While there was information that was over three months old, “the evidence was not stale because it described a firmly entrenched, widespread, and continuing narcotics trafficking organization.” There is nexus to the home of those involved in drug trafficking as a place where the drugs would be kept. Furthermore, GPS tracking on a cell phone used in drug trafficking put it regularly at the home, and there were officer observations of comings and goings to the home. United States v. Silva, 2012 U.S. Dist. LEXIS 183043 (W.D. Wash. December 31, 2012):

The Ninth Circuit has recognized that “[i]n the case of drug dealers, evidence is likely to be found where the dealers live.” United States v. Terry, 911 F.2d 272, 276 (9th Cir. 1990) (quoting United States v. Angulo-Lopez, 791 F.2d 1394, 1399 (9th Cir.1986)). Under the law of this Circuit, the Affidavit’s details regarding Palacios-Rodriguez’s lengthy involvement in the DTO, including supplying cocaine to others in the conspiracy and participating in other narcotics transactions while living at the Edmonds Apartment, was sufficient basis to believe that contraband might be found at the residence. …