Cited by

n.1 (Minn. 1984) (stating that the reputation and previous convictions of search-warrant subject can support an issuing magistrate’s probable-cause determination); -16 (Minn. 1978) (determining that information that the police obtained independently from other sources id

at 622-23; (upholding warrant where totality of the circumstances showed drug sales being conducted at residence, which established clear nexus between drug dealing and residence to be searched); (affirming warrant based upon inference that defendant sold

d 671, 672-74 (Minn. 1984).

See State v. Cavegn , (stating that a clearer nexus can be established when there is direct information that a sale occurred at a specific residence).

Cavegn , -74 (Minn. 1984).

22, 2006); -74 (Minn. 1984) (comparing time -sensitive evidence of mere drug possession to more enduring evidence of ongoing drug sales); (reasoning that people who sell drugs likely would maintain evidence of the crime in their residence), review denied (Minn. Nov

In support, he notes “that absent additional facts tending to show otherwise, a one-shot type of crime, such as a single instan ce of possession or sale of some form of contraband, will support a findi ng of probable caus e only for a few days at best.”

“In general, a single incident of criminal activity, such as a sale of contraband, ‘will support a finding of probable cause only for a few days at best.’” ( (citation omitted)).

The supreme court has said that a “one-shot type of crime, such as a single instance of possession or sale of some form of contraband, will support a finding of probable cause only for a few days at best.” State v. Cavegn

ch warrant); see also United Stated v. Jeanetta, 533 F.3d 651, 655 (8th Cir. 2008) (concluding that probable cause was not stale because of two-week delay between receipt of information and issuance of search warrant); DeWald, d at 746 –48 (concluding, in murder case, that three -week- old information contained in affidavit supporting search warrant was not stale); –74 (Minn. 1984) (concluding that probable cause was not stale whe n search warrant stated that “within the past week” a controlled

For example, a span of weeks between initial information of illegal activity and the warrant application is permissible when the activity involves 9 “repeated sales of drugs.” (quotation omitted).

For example, a span of weeks between initial information of illegal activity and the warrant application is permissible when the activity involves “ repeated sales of drugs.” (quotation omitted).

See State v. Cavegn , (stating that “[i]n a long line of cases,” the Minnesota Supreme Court has upheld affidavits when the affidavit was based on “the inde pendent police observation of a so-called ‘controlled purchase’”).

673 n. 1 (Minn.1984) (stating that “a defendant’s prior convictions, if relevant, may be considered on the issue of probable cause”); see also McCloskey, d at 704 (stating that even a defendant’s “relatively minor trouble with the law” is of “some” probative value in determining probable cause).

In general, a single incident of criminal activity, such as a sale of contraband, “will support a finding of probable cause only for a few days at best.” (quoting 1 La-Fave, Search & Seizure § 3.7(a) at 684 (1978)).

See, (holding that clear “object-place nexus” between drug dealing and residence searched was established by the fact that the sale actually occurred at the residence); -79 (Minn.1982) (establishing direct connection to residence when suspect was seen to enter her resid

See, (sufficient connection between illegal items and place to be searched, or “object-place nexus,” because the affidavit contained information that a sale of drugs actually occurred at the alleged dealer’s home); (sufficient nex *19 us for a warrant to sear