Affidavit was "Minimally Sufficient" to Support Search Warrant

United States v. Chambers, 882 F.3d 1305 (10th Cir. 2018) (OK, published): Chambers argued that an affidavit supporting a search warrant application did not include the address of his residence in the ‘residence to be searched’ paragraph and so lacked factual support. Without that support it was unreasonable for officers to rely in good faith on the warrant and the firearms found in his home had to be suppressed. The panel disagreed. It held that the affidavit established a minimally sufficient nexus between the criminal activity and the residence. The officer’s affidavit said that methamphetamine dealers, like the couple he was pursuing, kept items at their residences related to drug dealing; the couple lived at Chamber’s home; and Chamber’s home was located at the address listed in the affidavit (even if it wasn’t in the ‘residence to be searched paragraph’). Besides the affidavit included a satellite photo of the area, identifying the road on which the house was located and an arrow pointing to the ‘residence to be searched.’