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463 Mass. 353 - Appellee Commonwealth Brief - Mass Cases

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Blake, 413 <strong>Mass</strong>. 823, 828 (1992).<br />

Nexus<br />

The search warrant application also provided a<br />

sufficient nexus between drug activity and the Mendes<br />

apartment. The legal standards here are also well­<br />

understood. Sufficient nexus between the crime and the<br />

location to be searched may be found in the type of<br />

crime, the nature of the items sought, the suspect's<br />

ability to conceal such items, and normal inferences as<br />

to where a defendant would hide these items.<br />

<strong>Commonwealth</strong> v. Cinelli, 389 <strong>Mass</strong>. 197, 213 (1983).<br />

Here, the affidavit stated that CSA personally<br />

observed the defendants conduct over twenty cocaine and<br />

marijuana sales within their apartment. (I.R.A. 6.)<br />

CSA saw that the defendants weighed and packaged the<br />

cocaine within the confines of their residence and<br />

provided information about where a digital scale was<br />

stored. (I.R.A. 7.) CSA also gave information about<br />

where the drugs would be found within the home, stating<br />

that Raymond Mendes stored cocaine in his bedroom<br />

closet, that Ronald Mendes stored marijuana inside of<br />

his bedroom, and that a large amount of cocaine was in<br />

the basement. (I.R.A. 6-7.) This information,<br />

together with the two police-observed controlled buys<br />

20

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