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motion to suppress, concluding “that the detached garage); United States v. Gahagan, 865
description of Melancon’s property provides no F.2d 1490, 1492, 1499 (6th Cir. 1989); United
basis for the invalidation of the search.” States v. Prout, 526 F.2d 380, 386 (5th Cir. 1976)
Turning to the case at bar, in determining the place (warrant that authorized search of address of real
to be searched as 1015 East Cliff Drive, the agents estate office authorized search of apartment with
relied on the Gourmet corporate documents listing separate address “[g]iven the physical layout of
the West Coast Regional Office at that address, the premises and their use by [the defendants], as
including “the latest Gourmet employee phone observed by surveillance officers” because both
directory and office listing,” and a phone and fax premises shared a common foyer and “there was
number listed for the that address. They reviewed little likelihood that the wrong premises would be
photographs and satellite imagery, drove past the searched”).
location, and relied on information provided by
Sliz. Though the Government could have done The Sixth Circuit has upheld a search where the
more and with additional research may have officers searched a building not described in the
discovered the separate addresses, it was warrant and located at an address not listed in the
reasonable to believe that the address listed on the warrant. The warrant in that case listed and
company documents as the West Coast Regional described only 7609 Douglas Lake Road, one of
Office was in fact the address of the office. four separate dwellings in the rural area, as the
Moreover, no signs or markings indicated that the place to be searched, but the officers searched one
home office carried a separate address, and both other nearby dwelling that carried a separate
structures were similar in appearance, were address. The Sixth Circuit determined that the
contained on a singular rectangular lot within the search was valid because one of the officers
same fenced area, appeared to be connected by the involved in executing the warrant was also the
same utility wires, and were connected by a affiant on the application for the warrant, the
sidewalk. Under the circumstances, the officers search was confined to the areas that the officer
acted reasonably and in good faith in not including described, and the officer “conducted a pre search
the address 1015½ East Cliff in the warrant briefing session for those officers who
application and in believing that the warrant for participated in the search and provided them a
1015 East Cliff Drive covered both buildings. description of the premises to be searched.”
We next determine whether the officers were Specifically, that court held “that when one of the
objectively reasonable and acting in good faith in executing officers is the affiant who describes the
their belief that the warrant containing a physical property to the judge, and the judge finds probable
description of only the primary residence cause to search the property as described by the
authorized the search of a separate building affiant, and the search is confined to the areas
behind the primary residence. Based on the which the affiant described, then the search, in this
circumstances of this case, we conclude that they case, is in compliance with the fourth
were. amendment.” We have previously approved the
practice of referencing the affidavit supporting the
Our court and others have upheld searches where warrant where “the warrant is ambiguous, but
the warrant lacked a physical description of a fairly directs attention to the place actually
second location searched by the officers. See searched.” See United States v. Haydel, 649 F.2d
United States v. Bansal, 663 F.3d 634, 663 (3d Cir. 1152, 1156-57 (5th Cir. 1981). In that case, we
2011) (warrant that authorized search of concluded:
“premises” at address authorized search of

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