Merely alleging in a search warrant application that drug dealers usually keep drugs at home does not satisfy the nexus requirement. It does, however, satisfy the good faith exception. Motion to suppress denied. United States v. Neal, 2022 U.S. Dist. LEXIS 223493 (W.D. Tenn. Dec. 12, 2022):
This information, and the executing officer’s understanding that when a “drug dealer is engaging in continual and ongoing operations, drug contraband is likely to be found in the drug dealer’s home,” form a minimal nexus between Defendant’s alleged drug dealing and his home such that the officer’s belief that it amounted to probable cause was not unreasonable. McCoy, 905 F.3d at 418. “When the police exhibit ‘deliberate,’ ‘reckless,’ or ‘grossly negligent’ disregard for Fourth Amendment rights, the deterrent value of exclusion is strong and tends to outweigh the resulting costs.” Davis v. United States, 564 U.S. 229, 236, 131 S. Ct. 2419, 180 L. Ed. 2d 285 (2011) (quoting Herring v. United States, 555 U.S. 135, 141, 129 S. Ct. 695, 172 L. Ed. 2d 496 (2009)). “But when the police act with an objectively ‘reasonable good-faith belief’ that their conduct is lawful, … the ‘deterrence rationale loses much of its force.'” Id. (quoting Leon, 468 U.S. at 919).