The following excerpt is from United States v. Flores, 802 F.3d 1028 (9th Cir. 2015):
Ultimately, we need not decide whether the warrant was overbroad for lack of a temporal limit because even if it was, suppression of the evidence used at trial was not required. We have embraced the doctrine of severance, which allows us to strike from a warrant those portions that are invalid and preserve those portions that satisfy the Fourth Amendment. Only those articles seized pursuant to the invalid portions need be suppressed. United States v. GomezSoto, 723 F.2d 649, 654 (9th Cir.1984). No evidence was introduced at trial that should have been suppressed under this standard, regardless of the warrant's potential overbreadth. Indeed, the two sets of Facebook messages introduced at trial were sent on the day of Flores's arrest and thus fell well-within even the narrowest of
[802 F.3d 1046]
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