Bower v. State
In Bower v. State, 769 S.W.2d 887, 905 (Tex. Crim. App. 1989), the appellant was suspected of murder committed during the course of stealing an aircraft. Bower, 769 S.W.2d at 894-95.
The search warrant authorized the search of Bower's house and three particularly described vehicles. Id. at 905.
The officers had probable cause to believe the suspect possessed certain evidence, but they were not sure where at his residence such evidence might be found. Id.
Bower asserted that there was no probable cause to show that the evidence sought would be located in any of the three identified cars. Id.
In analyzing how detailed the description of the location of the item sought must be, the court concluded that Tex. Code Crim. Proc. article 18.01 "merely requires that there be probable cause to believe that the items would be located in the general location, i.e., somewhere within appellant's residence, which included the automobiles parked inside his garage and on the premises. To require anything more specific would be to require the impossible." Id.