M.D.Ga.: Address and GPS coordinates particular enough for SW

“The address and GPS coordinates alone would prevent another premise from being mistakenly searched. Moreover, the knowledge of the executing officer can be considered in determining the sufficiency of the description. See United States v. Sturmoski, 971 F.2d 452, 458 (10th Cir. 1992); see also United States v. Musson, 650 F.Supp. 525, 538 (D. Colo. 1986). As the affiant was also the executing officer, his knowledge of the property would have enabled the officers to locate the premises to be searched. Under these circumstances, the Court finds no descriptive defect in the search warrant.” The warrant was a state warrant, so it’s not subject to Rule 41. United States v. Fowler, 2013 U.S. Dist. LEXIS 110922 (M.D. Ga. August 7, 2013). [Seriously: GPS coordinates aren’t good enough to find a particular place?]

Defendant was stopped for unsafe driving, and reasonable suspicion developed primarily because they were driving from Boston to Cincinnati and back without staying over and air freshener in the back of the van. That and the lengthy computer check justified a 24 minute detention for the drug dog to complete his trip around the vehicle. State v. Thomas, 2013 Ohio 3411, 2013 Ohio App. LEXIS 3501 (August 2, 2013).*

A closed bin with an ill fitting lid was found in a woman’s closet in the place defendant was staying it. She had apparent authority to consent to its search. United States v. Mujahid, 2013 U.S. Dist. LEXIS 110237 (N.D. Ill. August 6, 2013).*

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