State v. Aguilar, 1602005623

Defendant Cristo J. Aguilar charged with drug dealing and aggravated possession of marijuana after two controlled buys in January 2016.
A reliable confidential informant (CI) arranged two buys; police confirmed Aguilar’s address and vehicle via DELJIS and observed the transactions.
On both occasions officers saw Aguilar leave his residence in a silver Honda Civic, complete the drug sale with the CI, then return directly to the residence.
Affidavits for warrants included the CI corroboration, the observed travels tying Aguilar, the Vehicle, and the Residence to the sales, and an officer’s expert opinion that dealers store proceeds/records at home and use multiple locations to conceal contraband.
Aguilar moved to suppress evidence seized from the Vehicle and Residence, arguing the affidavits failed to show a nexus between the crimes and those locations.
The court applied a four-corners probable-cause review, gave deference to the magistrate, and denied the suppression motion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether affidavits established probable cause linking the Residence to drug sales	Warrants valid: observed trips from Residence to sales, CI corroboration, and officer expertise create reasonable nexus	Affidavits lack direct evidence placing contraband at the Residence; reliance on expert opinion insufficient	Denied — magistrate had substantial basis: observed immediate returns to Residence after buys, one order placed while Aguilar was at Residence, plus expert opinion supported the nexus
Whether affidavits established probable cause linking the Vehicle to drug sales	Vehicle was the means transporting drugs/proceeds between sales and Residence; observations tied it to transactions	Argues insufficient nexus beyond mere presence at transactions and residence	Denied — Vehicle was directly linked as the transport between sales and Residence, supporting probable cause

Pierson v. State, 338 A.2d 571 (Del. 1975) (four-corners review for search warrant affidavits)
State v. Sisson, 883 A.2d 868 (Del. Super. 2005) (defendant bears burden to show warrant affidavit insufficient)
Dorsey v. State, 761 A.2d 807 (Del. 2000) (probable cause to arrest does not alone justify a home search)
State v. Holden, 60 A.3d 1110 (Del. 2013) (deference to issuing magistrate reviewing warrants)
United States v. Ribeiro, 397 F.3d 43 (1st Cir. 2005) (direct travel from home to drug sale plus expert opinion can establish nexus)
United States v. Stearn, 597 F.3d 540 (3d Cir. 2010) (probable cause to search residence where defendant left property before controlled buy and returned with proceeds)
United States v. Burton, 288 F.3d 91 (3d Cir. 2002) (seller’s return home after a purchase supports inference home stores proceeds/evidence)
Hicks v. United States, 575 F.3d 130 (1st Cir. 2009) (officer following defendant back to residence after controlled purchase can create nexus)