What is the scope of a search warrant for seizure of immigration papers, medical records, and all records relating to prescription drugs?

MultiRegion, United States of America

The following excerpt is from U.S. v. Sangha, 930 F.2d 30 (9th Cir. 1991):

We conclude that the search warrant was sufficiently precise. As we stated in United States v. Hernandez-Escarsega, 886 F.2d 1560, 1567 (9th Cir.1989), " '[a] warrant need only be reasonably specific in its description of the objects of the search and need not be elaborately detailed.' " (quoting United States v. Hayes, 794 F.2d 1348, 1354 (9th Cir.1986) (citation omitted), cert. denied, 479 U.S. 1086 (1987). The warrant in dispute identified the type of immigration papers to be seized, and did not allow for "exploratory rummaging in a person's belongings." Rabe, 848 F.2d at 997 (quotation omitted).

Moreover, we have upheld search warrants that were far less specific than the one in the case at bar. See Rodriguez, 869 F.2d at 486 (upholding warrant allowing for search of "articles of personal property tending to establish the existence of a conspiracy to sell cocaine, consisting of and including personal telephone books, address books...."); United States v. Hayes, 794 F.2d 1348, 1350 (9th Cir.1986) (authorizing seizure of controlled substances and "all records which document the purchasing, dispensing and prescribing of controlled substances, including, but not limited to, records contained in patient charts and all relevant records required to be maintained ... patient logs, appointment books....").

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