California, United States of America
The following excerpt is from People v. Wilson, 256 Cal.App.2d 411, 64 Cal.Rptr. 172 (Cal. App. 1967):
It has been held that the burden of establishing the invalidity of a search warrant is upon the defendant. (Williams v. Justice Court (1964) 230 Cal.App.2d 87, 97--98, 40 Cal.Rptr. 724.)
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