A rose by any other name establishes probable cause?

The limits of the Leon good-faith exception were expanded ever wider in today's opinion in United States v. Rose.  There, several minors told officers that Mr. Rose had sexually assaulted them in his bedroom and shown them child pornography.  Officers prepared a warrant to search 709 Elberon Ave., describing the house and the fact that the house had the name "Rose" over the doorbell.  The warrant stated that Mr. Rose was the subject of the search.  The warrant affidavit, however, failed to include the property's address, and failed to establish any nexus between Mr. Rose and the property being searched.  In other words, the affidavit linked Mr. Rose to evidence of criminal activity (the sexual assaults, the pornography), but it failed to state that any such criminal activity occurred at the address or even that Mr. Rose lived at that address.

The Sixth Circuit had no trouble finding that the failure to establish the requisite nexus meant that the affidavit did not establish probable cause.  Ever since Leon, however, defense attorneys have known that the inquiry does not end there.  Under the good-faith exception, the court asserted that the affidavit was not "bare-bones," and, indeed, the only problem with it was that it "fails to connect Rose with 709 Elberon Ave."  That's not a small problem, especially where the officers preparing the warrant affidavit are the same ones executing it (not entirely clear here) and thus would have reason to know of the deficiency.  The court, however, suggests that failing to establish any nexus between the criminal activity and the address to be searched is more akin to "clerical error." 

While the court takes pains to situate the holding within the specific facts of this case, nexus claims will seem all the more daunting after Rose.