The following excerpt is from U.S. v. Zapata-Galvez, 9 F.3d 1555 (9th Cir. 1993):
Zapata contends that the decision in United States v. Ramos, 923 F.2d 1346 (9th Cir.1991), supports his position that these observations do not create probable cause. In Ramos, the court found that probable cause did not exist to issue a warrant to search an apartment and storage area because the affidavit did not show a nexus between the criminal activity and the places to be searched. Id. at 1353. Although the affidavit recounted conduct typical of narcotics traffickers, the court noted that the affidavit contained no evidence connecting the apartment to the items sought.
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