What is the scope of a search warrant for "material evidence of violation" under 18 U.S.C. 841, 846?

MultiRegion, United States of America

The following excerpt is from U.S. v. Brown, 951 F.2d 999 (9th Cir. 1992):

1 The affidavits provided specific addresses and locations at those addresses which were authorized to be searched. In addition, the warrants provided a highly detailed list of the items authorized to be seized, including "large quantities of United States currency; cashier's checks ... indicating a remitter to be an individual other than the individual purchasing the check ...; indicia of occupancy, residency or ownership of the premises ... including utility bills, telephone bills ...; airline tickets, travel agency billings ... relating to travel which are the fruits, instrumentalities, and evidence of violations of 18 U.S.C. 1956(a), 1951, 1952, 1343...." Compare United States v. Crozier, 777 F.2d 1376, 1381 (9th Cir.1985) (warrant authorizing search for "[m]aterial evidence of violation [of] 21 USC 841, 846" facially deficient, precluding reasonable reliance).

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