context: 15 Errors in an affidavit do not require suppression when the magistrate has a substantial basis to determine that the erroneous facts are merely typographical errors and the facts otherwise support a determination of probable cause.
citation_a.signal: see
citation_a.identifier: 45 M.J. 406, 420
citation_a.parenthetical: declining to invalidate a warrant based on an affidavit in which a serivener's error changed a username from "Reddel" (ending with a numeral) to "REDDEL" because the Federal Bureau of Investigation was otherwise "clear that they were searching" for the former
citation_a.sentence: See, e.g., State v. Valle-Flores, 2005 UT App 290, ¶¶ 2-5, 117 P.3d 1069 (holding that a warrant to search 626 Pueblo Street was supported by probable cause despite the supporting affidavit's reference to both 624 Pueblo Street and 626 Pueblo Street); State v. Wallace, 2002 UT App 295, ¶¶ 24-26, 55 P.3d 1147 (holding that a warrant to obtain a blood sample was valid despite a reference to a urine sample in the addendum to the affidavit because the "minor inconsistency" did "not seriously undermine the information underlying the probable cause determination"); United States v. Snyder, 471 Fed.Appx. 884, 885 (11th Cir.2012) (per curiam) (holding that an affidavit that gave directions to 1924 Queen City Avenue and included a description of the numberplate and building at that location provided sufficient probable cause to validate a search warrant despite also containing a single reference to 1942 Queen City Avenue); United States v. Maxwell, 45 M.J. 406, 420 (C.A.A.F. 1996) (declining to invalidate a warrant based on an affidavit in which a serivener's error changed a username from "Reddel" (ending with a numeral) to "REDDEL" because the Federal Bureau of Investigation was otherwise "clear that they were searching" for the former); see also State v. Rosario, 238 Conn. 380, 680 A.2d 237, 240-41 (1996) (concluding that an affidavit's misstatement of the year did not undermine probable cause where other information in the affidavit indicated the correct year); State v. White, 368 So.2d 1000, 1002 (La.1979) (same); State v. Marquardt, 48 Or.App. 515, 603 P.2d 1198, 1199 (1979) (same); 2 Wayne R. LaFave, Search and Seisure § 8.7), at 496 (5th ed. 2012) ("[Rleference to a year other than the current year will not invalidate the warrant if the circumstances fairly indicate that the intended reference was to the current year.").
citation_b.signal: see also
citation_b.identifier: 680 A.2d 237, 240-41
citation_b.parenthetical: concluding that an affidavit's misstatement of the year did not undermine probable cause where other information in the affidavit indicated the correct year
citation_b.sentence: See, e.g., State v. Valle-Flores, 2005 UT App 290, ¶¶ 2-5, 117 P.3d 1069 (holding that a warrant to search 626 Pueblo Street was supported by probable cause despite the supporting affidavit's reference to both 624 Pueblo Street and 626 Pueblo Street); State v. Wallace, 2002 UT App 295, ¶¶ 24-26, 55 P.3d 1147 (holding that a warrant to obtain a blood sample was valid despite a reference to a urine sample in the addendum to the affidavit because the "minor inconsistency" did "not seriously undermine the information underlying the probable cause determination"); United States v. Snyder, 471 Fed.Appx. 884, 885 (11th Cir.2012) (per curiam) (holding that an affidavit that gave directions to 1924 Queen City Avenue and included a description of the numberplate and building at that location provided sufficient probable cause to validate a search warrant despite also containing a single reference to 1942 Queen City Avenue); United States v. Maxwell, 45 M.J. 406, 420 (C.A.A.F. 1996) (declining to invalidate a warrant based on an affidavit in which a serivener's error changed a username from "Reddel" (ending with a numeral) to "REDDEL" because the Federal Bureau of Investigation was otherwise "clear that they were searching" for the former); see also State v. Rosario, 238 Conn. 380, 680 A.2d 237, 240-41 (1996) (concluding that an affidavit's misstatement of the year did not undermine probable cause where other information in the affidavit indicated the correct year); State v. White, 368 So.2d 1000, 1002 (La.1979) (same); State v. Marquardt, 48 Or.App. 515, 603 P.2d 1198, 1199 (1979) (same); 2 Wayne R. LaFave, Search and Seisure § 8.7), at 496 (5th ed. 2012) ("[Rleference to a year other than the current year will not invalidate the warrant if the circumstances fairly indicate that the intended reference was to the current year.").