NY3: SW address for 1013 Pleasant second floor permitted search when it was actually 1015 Pleasant

The address of the place to be searched in the warrant was 1013 Pleasant Street, second floor. The second floor, however, was 1015 Pleasant Street, and it was searched. The warrant is not to be view hypertechnically, and it adequately described the place to be searched and it was searched. People v. Roberts, 2022 NY Slip Op 02157, 2022 N.Y. App. Div. LEXIS 2051 (3d Dept. Mar. 31, 2022).

The ongoing nature of the alleged crime made the search warrant affidavit for defendant’s cell phone not stale. United States v. Middleton, 2022 U.S. Dist. LEXIS 58829 (N.D.Ga. Mar. 30, 2022).*

Officers had a search warrant for defendant’s premises. His flight from the premises and interferences supported search of his car parked outside, too, under the automobile exception. United States v. Offutt, 2022 U.S. Dist. LEXIS 58915 (S.D.Ill. Mar. 30, 2022).*

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