Taylor v. State, 303 Ga. 57

In July 2008 police obtained a warrant to search 1751 Bergen Court for cameras, computers, and electronic storage devices for evidence of child molestation and sexual battery.
The supporting affidavit (and an incorporated Attachment A) described multiple sexual assaults occurring at “Taylor’s,” “Taylor’s residence,” and specific locations within “Mr. Taylor’s house,” but never explicitly stated that Taylor lived at 1751 Bergen Court.
Taylor moved to suppress the evidence seized from 1751 Bergen Court on the ground that the affidavit failed to establish a nexus between him and that address, so the magistrate lacked probable cause to issue the warrant.
The trial court denied the motion; after conviction, the Court of Appeals affirmed, adopting a rule allowing inference of residence when an affidavit links a single place to the suspect and lists a specific address.
The Supreme Court of Georgia granted certiorari to decide whether inferences from the affidavit may suffice to connect the suspect to the listed address and thus to support probable cause for the search.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether an affidavit that does not expressly state the suspect lives at the listed address can still establish a nexus between the suspect and the place to be searched	Taylor: affidavit fails to show 1751 Bergen Court is his residence, so no nexus and no probable cause	State: the affidavit and Attachment A repeatedly link the evidence to "the location described herein" (1751 Bergen Court) and to "Taylor's residence," permitting a common-sense inference that Taylor lived there	Held: Yes — magistrate could reasonably infer the nexus; affidavit sufficient and warrant valid
Whether the Court of Appeals’ broader rule (that a single place described and a listed address necessarily imply the same) was required here	Taylor: argued the Court of Appeals’ rule was not supported by the affidavit	State: argued inference approach appropriate under Gates and deference to magistrate	Held: The Court affirmed the result but said the Court of Appeals’ broad formulation was unnecessary in this case because the affidavit itself supplied sufficient facts to support the inference

Illinois v. Gates, 462 U.S. 213 (establishes the totality-of-the-circumstances/probable-cause standard and that magistrates may draw reasonable inferences)
State v. Trujillo, 266 P.3d 1 (N.M. 2011) (endorses a common-sense inference that a described residence is the place to be searched when only one place is tied to the suspect)
United States v. Hunter, 86 F.3d 679 (7th Cir. 1996) (discusses deference to magistrate and reasonable inferences in assessing probable cause)
State v. Hunter, 282 Ga. 278 (discusses Georgia standard for magistrate probable-cause determinations and deference on review)
United States v. Rose, 714 F.3d 362 (6th Cir. 2013) (affidavit must connect defendant or activity to the address; distinguishing fact patterns where no nexus exists)
United States v. Laughton, 409 F.3d 744 (6th Cir. 2005) (invalidated warrant where affidavit failed to connect residence to criminal activity or defendant)
United States v. Gonzales, 399 F.3d 1225 (10th Cir. 2005) (government conceded affidavit lacked connection between place to be searched and alleged criminal activity)