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A search-warrant affidavit must contain proof “of facts so closely related to the time of the issue of the warrant as to justify a finding of probable cause at that time.” (quoting Sgro v. United States, 287 U.S. 206, 210 (1932)).

“To determine whether the issuing court had a substantial basis for finding probable cause to search [a place], we look to the ‘totality of the circumstances’ test for probable cause.”

A fair probability requires “a direct connection, or nexus, between the alleged crime and the particular place to be searched.”

“In determining probable cause, [courts] must consider the ‘veracity’ and ‘basis of knowledge’ of persons supplying hearsay information.” (quoting Illinois 3 The state argues that this drug-wholesaler inference is sufficient on its own to support probable cause.

(articulating circumstances (1) through (3)); Harris, d at 788 (articulating circumstances (4) through (7)).

A search-warrant application must include “facts so closely related to the time of the issue of the warrant as to justify a finding of probable cause at that time.” (quotation omitted).

-50 (Minn. 1998) (finding insufficient nexus where affidavit lacked information showing the defendant was a drug trafficker, “much less that she performed such acts from her home”).

(articulating one through three); (articulating four through seven).

A search-warrant application must include “facts so closely related to the time of the issue of the warrant as to justify a finding of probable cause at that time.” (quotation omitted).

A valid search warrant must have “a direct connection, or nexus, between the alleged crime and the particular place to be searched, particularly in cases involving the search of a residence for evidence of drug activity.” -48 (Minn. 1998).

At times, information can be too old to support a reasonable search and is therefore “stale.”

Consistent with binding precedent, the following factual recitation begins by summarizing the information set forth in the search-warrant affidavit1 before turning to an overview of the trial evidence, presented in the light most favorable to and consistent with the jury’s verdicts.2 1 d 138, 145 (Minn. 2024)

“When the request of the court is for the issuance of a warrant to search a particular location, there must be specific facts to establish a direct connection between the alleged criminal activity and the site to be searched.”

there is a fair probability that contraband or evidence of a crime will be found in a particular place.” (quoting Illinois v. Gates, 462 U.S. 213, 238 (1983)).

In the first opinion, the warrant application stated that the appellant had used drugs at parties, had purchased drugs, and had had numerous telephone calls with known drug dealers.

ion and parked a 1973 Mercedes in front of that address “len[t] credence” to the tip); McCloskey, d at 701, 703 (determining that a CRI’s tip was sufficiently reliable where the police corroborated that the residence in the CRI’s tip was owned by the subject of the tip and verified that the phone number provided by the CRI belonged to the warrant-application subject); 750 (Minn. 1998) (determining that a CRI’s tip was sufficiently reliable where the police corroborated calls between the warrant-

Validity of the Search Warrant An appellate court’s review of the validity of a search warrant “is limited, with great deference afforded to the issuing court.” State v. Souto , State v. Rochefort , (noting that, while a determination of whether probable cause existed to support a search warrant is reviewed de novo, this court gives “great deference” to the issuing magistrate’s determination of probable cause at the time of the warrant’

The warrant must allege “specific facts to establish a direct connection between the alleged criminal activity and the site to be searched.”

6 “whether there is any indication of ongoing criminal activity, whether the articles sought are innocuous or incriminating, whether the property sought is easily disposable or transferable, and whether the items sought are of enduring utility.”

between the alleged crime and the particular place to be searched.”

Reviewing courts look for “a direct connection, or nexus, between the 12 alleged crime and the particular place to be searched, particularly in cases involving the search of a residence for evidence of drug activity.” - 48 (Minn. 1998).

“Elements bearing on this probability include information linking the crime to the place to 7 be searched and the freshness of the information.”

We review an appellant’s contention that a warrant rests on an insufficient factual ground by examining the warrant application to determine whether a substantial basis justifies the district court’s probable-cause determination, including whether it outlines facts that connect the site with the criminal activity

“Elements bearing on this probability include information linking the crime to the place to be searched and the freshness of the information.”

The Minnesota Supreme Court explained that probable cause requires “a direct connection, or nexus, between the a lleged crime and the particular place to be searched.”

“Elements bearing on this probability include information linking the crime to the place to be searched and the freshness of the information.”

A search-warrant application must state “‘facts so closely related to the time of the issu[ance] of the warrant as to justify a finding of probable cause at that time.’” (quoting Sgro v. United States, 287 U.S. 206, 210, 53 S. Ct. 138, 140 (1932)).

State v. Souto , –748 (Minn. 1988 ).

Probable cause requires specific facts establishing a “nexus”—“a direct connection between the alleged criminal activity and the site to be searched.” State v. Souto

“The proof must be of facts so closely related to the time of the issue of the warrant as to justify a finding of probable cause at that time.” (quotation omitted) .

A sufficient nexus between the alleged criminal activity and the 5 place to be searched is required, “particularly in cases involving the search of a residence for evidence of drug activity.” -48 (Minn. 1998).