United States v. Smith, No. 12-2948 (8th Cir. 2013)
Annotate this CaseDefendant pleaded guilty to five counts of distribution of cocaine base and subsequently appealed his conviction. The court concluded that the incorrect date on the warrant was a "technicality issue" that did not invalidate the warrant; the magistrate judge's clerical error did not defeat probable cause; the district court did not err in denying defendant's motion for judgment of acquittal, rejecting defendant's claim that the district court should have excluded the evidence discovered during the search of his residence; the government did not fail to establish that defendant lived at the residence where much of the evidence was discovered; and defendant's confession, combined with the evidence discovered during the controlled buys, trash pull, and search of his residence, was sufficient evidence to support his conviction. Accordingly, the court affirmed the judgment of the district court.
Court Description: Criminal case - Criminal law. Incorrect date on search warrant was a "technicality issue" that did not invalidate the warrant, and the magistrate's error in completing the warrant did not defeat probable cause; evidence was sufficient to support defendant's drug and gun convictions.
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