Opinion
NO. 2018 KW 1621
12-26-2018
In Re: State of Louisiana, applying for supervisory writs, 21st Judicial District Court, Parish of Tangipahoa, No. 1800359. BEFORE: GUIDRY, THERIOT, AND PENZATO, JJ.
WRIT GRANTED. As a general rule, mistakes in the use of municipal numbers do not invalidate a search warrant which otherwise describes the premises with sufficient particularity such that the officer with the warrant can with reasonable effort ascertain and identify the place intended. State v. Alonzo, 95-2483 (La. 5/31/96), 675 So.2d 266, 267 (per curiam). Furthermore, enough measures were taken to ensure the search occurred at the correct location, and the wrong address on the warrant was a mistake and not the result of police misconduct. See United States v. Leon, 468 U.S. 897, 104 S. Ct. 3405, 82 L.Ed.2d 677 (1984). See also State v. Guidry, 2003-1944 (La. 11/21/03), 862 So.2d 965, 966 (per curiam). Accordingly, the ruling granting the motion to suppress is reversed, and this matter is remanded for further proceedings.
JMG
MRT
AHP
COURT OF APPEAL, FIRST CIRCUIT /s/_________
DEPUTY CLERK OF COURT
FOR THE COURT