In United States v. Griffin, 827 F.2d 1108 (7th Cir. 1987), cert. denied, 485 U.S. 909 (1988), the search warrant in question authorized the search of premises described as a one-story frame house and a detached garage at a stated address.
The officers executing the warrant not only searched the house and garage but also searched a tool shed in the backyard and an automobile in the driveway, and seized items from soil and rock in the backyard.
The court noted that "the better practice would be to specify clearly in the warrant whether the entire premises or only some building on or portions of the premises are subject to search." 827 F.2d at 1115.
It held, however, that the search was not limited by the absence of specific reference in the warrant to each and every building on the "premises." Id.