State v. Webber, 383 P.3d 951

Defendant challenged a warrant to search his home for drug evidence; motion to suppress denied, then reversed on appeal.
Deputy Ritter's affidavit described CI-controlled buys from Benavente linking defendant to drug activity.
Observations showed Benavente meeting with defendant before/after buys and a hand-to-hand exchange through a vehicle window near the time of the buys.
The CI provided a baggie of cocaine obtained from Benavente, and a separate controlled buy occurred the day before the warrant request.
Defendant was present at another buy; later, a Durango search triggered a canine alert but found no incriminating items on the vehicle or in defendant’s possession.
The affidavit asserted defendant’s involvement in drug dealing but largely relied on Ritter’s training and experience to connect that activity to defendant’s home, which the trial court accepted, but the Court of Appeals disagreed and remanded for suppression

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the affidavit established a nexus between the drug activity and defendant’s home	State relied on Ritter’s training to connect activity to home	No objective facts tying activity to home; training alone insufficient	Affidavit failed to establish the nexus; suppression reversed
Whether training and experience can supply the necessary nexus when objective facts are weak	Training strengthens probable cause under Goodman framework	Training cannot replace objective facts; not enough here	Training and experience not sufficiently tied to objective facts; warrant invalid; remand for suppression

State v. Goodman, 328 Or 318 (1999) (test for nexus between suspected crime and location; objective facts plus expert grounding needed)
State v. Castilleja, 345 Or 255 (2008) (reviewing warrant legality; legal question of probable cause)
State v. Wilson, 178 Or App 163 (2001) (facts too weak to be shored up by expertise)
State v. Miller, 254 Or App 514 (2013) (affidavit insufficient where activity not tied to home and no nexus)
State v. Chamu-Hernandez, 229 Or App 334 (2009) (recognizes officer expertise may create nexus when facts support)
State v. Villagran, 294 Or 404 (1983) (scale/sophistication of operation can support nexus to home)
State v. Harper, 197 Or App 221 (2005) (evidence of precursor or method can justify home search)
State v. Heyne / Yunke, 270 Or App 601 (2015) (affidavit linked car possession to home when direct connection exists)