AR: Wrong address on SW not fatal where affiant was executing officer and the right place was searched

The wrong address on the search warrant didn’t make the warrant unparticular where the officer applying for the search warrant observed two controlled buys there from a distance and then executed the warrant on the right place. Kellensworth v. State, 2021 Ark. 5,  2021 Ark. LEXIS 15 (Jan. 21, 2021):

Here, Agent Keathley twice watched the informant enter Kellensworth’s mobile home to buy drugs. Agent Smith watched once. Using this information, Agent Smith then applied for the search warrant. Both agents executed the warrant in person. There was minuscule risk the agents would search the wrong mobile home. We have noted before that “a search warrant is not automatically rendered invalid if it contains an incorrect address of the property to be searched.” Ritter v. State, 2011 Ark. 427, at 7, 385 S.W.3d 740, 744. There, we found the incorrect address on the warrant “was mitigated by the fact that the officers executing the warrant personally knew which premises were to be searched.” Id. at 8, 385 S.W.3d at 745.