The following excerpt is from United States v. Embry, No. 14-30110 (9th Cir. 2015):
2. "Whether a search warrant describes items to be seized with sufficient specificity is reviewed de novo." United States v. Reeves, 210 F.3d 1041, 1046 (9th Cir. 2000). Here, the search warrant fails to meet the requirements of the test set out in United States v. Spilotro, 800 F.2d 959, 963 (9th Cir. 1986), for determining whether a warrant is "sufficiently precise." As in Spilotro, the search warrant here "authorize[d] wholesale seizures of entire categories of items not generally evidence of criminal activity, and provide[d] no guidelines to distinguish items used lawfully from those the government had probable cause to seize." Id. at 964.
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