Whether a controlled drug transaction that takes place away from a suspect's home is sufficient to establish a nexus between the offense and the suspect's home, providing law enforcement with probable cause that drugs or contraband will be found in the home?

QUESTION PRESENTED Law enforcement obtained a warrant to search Mr. Windom’s apartment after he participated in a controlled buy of methamphetamine that took place away from his home. Other than the controlled buy, the only information linking the apartment to drug sales was months-old vague, uncorroborated information provided by an unnamed informant. Mr. Windom argued below that the controlled buy, having taken place outside of his home, was insufficient to establish the requisite nexus between the criminal activity and the place to be searched. The Tenth Circuit rejected Mr. Windom’s argument, noting that it had repeatedly held that is “merely common sense that a drug supplier will keep evidence of his crimes at his home.” United States v. Windom, Nos. 22-1077 and 22-1119, 2023 WL 2136499, *3 (10th Cir. Feb. 21, 2023). The question presented is: Whether a controlled drug transaction that takes place away from a suspect’s home is sufficient to establish a nexus between the offense and the suspect’s home, providing law enforcement with probable cause that drugs or contraband will be found in the home? i