What is the test for obtaining a search warrant for a crack cocaine factory in a residential street?

California, United States of America

The following excerpt is from People v. Camacho, 23 Cal.4th 824, 3 P.3d 878, 98 Cal.Rptr.2d 232 (Cal. 2000):

The reasoning in United States v. Fields, supra, 113 F.3d 313, is particularly instructive. In that case, the defendants used a ground-floor apartment to prepare crack cocaine. A known and reliable informant contacted the police to inform them of the defendants' activities. Believing that there was insufficient time to obtain a search warrant, the police officer who received the tip assembled a team of investigators to visit the apartment. Upon their arrival, the officers were unable to see into the windows of the apartment from the public sidewalk or street. The officers therefore entered a fenced-in rear yard and then a fenced-in side yard in order to facilitate their view into the building. At the rear of the side yard, the officers found a window covered with Venetian blinds, save for a five- to six-inch gap beneath the blinds. Upon looking in, the officers saw the defendants packaging what appeared to be crack cocaine. The officers ultimately forced open the locked back door with a battering ram and arrested the men. After obtaining a search warrant, the officers seized more than 400 grams of crack cocaine from the apartment.

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