## Facts

- Three armed bank robberies occurred in northeastern Ohio between June 1981 and January 1982; the robbers used weapons and rubber masks and stole large sums of money.
- Federal arrest warrants issued in April 1982 charged Thomas James Savoca and James Carey with the January 1982 robbery.
- FBI agents located Savoca in Phoenix, Arizona, and surveilled an Arizona motel where room 135 was registered under an alias used by Carey.
- Agents observed two men enter room 135 and later arrested Savoca and Carey as they exited; Carey was shot during an attempted reentry.
- After the arrests, agents obtained a warrant to search the motel room for “weapons, disguises, U.S. currency, and ficticious identification.”
- The supporting affidavit stated that Savoca and Carey had been arrested for an Ohio bank robbery and suspected in other Ohio robberies and that they had been seen in the motel room shortly before arrest; it did not state that the robberies occurred months earlier.
- Officers executed the warrant and seized items including handguns, masks, and false identification, which were admitted at Savoca’s Ohio bank-robbery trial, leading to conviction on two counts under 18 U.S.C. § 2113(a), (d).

## Issues

1. Whether the affidavit established probable cause to search the Phoenix motel room for evidence of the Ohio bank robberies by showing a sufficient nexus between the suspected crimes and the place to be searched.
2. Whether the affidavit’s failure to disclose that the robberies occurred months before the search prevented a proper staleness assessment and undermined probable cause.

## Decision

- The court reversed Savoca’s conviction and remanded for a new trial.
- The court held the search warrant invalid because the affidavit did not establish probable cause that evidence of the Ohio robberies would be found in the motel room.
- The court concluded that “presence plus arrest” in the room, combined with generalized suspicion of involvement in robberies, did not supply the required location-specific showing.
- The omission of the dates of the robberies was significant because it impaired the magistrate’s ability to evaluate whether the information was stale.

## Legal Principles

- A warrant requires a factual, location-specific nexus showing a fair probability that evidence of the suspected offense will be found at the place to be searched.
- A suspect’s arrest at a location does not, by itself, establish probable cause to conduct a full evidentiary search of that location under a warrant (as distinct from limited search-incident authority).
- Probable cause depends in part on time; an affidavit must provide enough temporal information to permit a meaningful staleness assessment.
- Generalized suspicion or a suspect’s alleged involvement in past crimes cannot substitute for facts connecting the targeted place to the items sought.

## Conclusion

The Sixth Circuit set aside the convictions because the warrant authorizing a broad search of the motel room was unsupported by probable cause: the affidavit failed to connect the room to evidence of the Ohio robberies and withheld timing information necessary to assess staleness, requiring suppression of the seized evidence and a new trial.


United States v. Savoca, 739 F.2d 220 (6th Cir. 1984)