State v. Thein
In State v. Thein (1999) 138 Wn.2d 133 977 P.2d 582, where a search warrant was issued based on evidence that the defendant was involved in drug dealing, and an officer's opinion that drug traffickers commonly keep drug inventory and paraphernalia, large sums of money, and weapons in their homes. The Washington Supreme Court found this showing insufficient to establish probable cause to search the defendant's residence, rejecting a "per se rule that if the magistrate determines a person is probably a drug dealer, then a finding of probable cause to search that person's residence automatically follows." (Id. at p. 585.)
The court concluded that "generalizations regarding the common habits of drug dealers" did not substitute for "specific facts linking such illegal activity to the residence searched. . . .. . . Although common sense and experience inform the inferences reasonably to be drawn from the facts, broad generalizations do not alone establish probable cause." (Id. at p. 589.)
The Supreme Court of Washington held that "most courts, however, require that a nexus between the items to be seized and the place to be searched must be established by specific facts; an officer's general conclusions are not enough." 977 P.2d at 588.
The Thein court ruled that evidence sufficient to permit an inference that the defendant was involved in drug dealing did not also establish a reasonable inference that evidence of the crime could be found in his residence. 977 P.2d at 590.