CA5: Counterfeiting SW supported seizure of firearm used in bank robbery

The search warrant was for counterfeiting, but the officers believed, but didn’t disclose to the USMJ, that the defendant was also involved in a bank robbery. The firearms in the bank robbery were found during the search, and they are not suppressed under the good faith exception. “The failure of the search-warrant application to reveal the possible connection of the firearms to the bank robberies did not render invalid the seizure of the firearms based on their possible relationship to Miller’s counterfeiting crimes. See United States v. Haydel, 649 F.2d 1152, 1159 (5th Cir. 1981).” United States v. Kizer, 554 Fed. Appx. 311 (5th Cir. 2014).