S.D.Ill.: Mistake in SW address didn’t mislead police; no IAC for not raising it

Mistakes in search warrant papers happen, and they don’t suppress the search unless they are meaningful and prejudicial to the process. Here, it was a wrong address cured by other things that sent the police to the right place. McBride v. United States, 2025 U.S. Dist. LEXIS 65303 (S.D. Ill. Apr. 4, 2025):

The case law on this is clear. Minor errors in search warrants-especially when it comes to addresses-do not automatically render a warrant invalid. E.g. United States v. Kelly, 772 F.3d 1072, 1081-82 (7th Cir. 2014), United States v. McMillian, 786 F.3d 630, 639-640 (7th Cir. 2015). “Minor technical errors or omissions do not automatically invalidate a warrant so long as there is no danger that the officers might inadvertently search the wrong place.” 772 F.3d at 1081. In other words, a warrant with an incorrect address complies with the Fourth Amendment so long as other portions of the supporting affidavit describes the location sufficiently enough for an officer to identify the correct location with reasonable effort.

Here, the warrant described the correct apartment, street, and street number. The address provided specified that the apartment in question was within Carbondale, Illinois. The warrant lists “E. Hester;” there is no other public road within the City of Carbondale named “East Hester” or “E. Hester;” nor is there a public road with either of those names within a 550-mile radius. Obviously, there is no way a reasonable officer would confuse the only street within city limits named “E. Hester” with another street named “E. Hester” more than 550 miles away when the address specifies the correct city and state. Thus, this claim is frivolous.