Washington v. Thein

In Washington v. Thein, 138 Wn.2d 133, 977 P.2d 582 (1999) the Washington Supreme Court held that generalizations made in an affidavit regarding the common habits of drug dealers were not, standing alone, sufficient to establish probable cause to search a person's residence, and that to support probable cause to search a person's residence, there must be facts establishing a link between a person's drug activity and a person's residence. The court further noted that there were even conflicts in the decisions of the Ninth Circuit Court of Appeals and that most courts require some nexus beyond an officer's general conclusions.