CA6: “[T]he warrant—although far from a model of careful drafting—satisfies the particularity requirement of the Fourth Amendment.”

The search warrant in this armed robbery case wasn’t proofread, reading the warrant “as a whole” it was clear what was sought, so the warrant was not general. “[T]he warrant—although far from a model of careful drafting—satisfies the particularity requirement of the Fourth Amendment.” United States v. Anderson, 555 Fed. Appx. 589 (6th Cir. 2014):

Here, although the warrant was inartfully drafted and apparently never proofread, it is not limited to a nonsequitur comparable to the warrant in Groh. Although Detective Coleman inserted a paragraph-length account of the Hampton Inn robbery in the space where a list of evidence should have appeared, the items to be seized can easily be gleaned from a “commonsense and realistic” reading of the warrant. See United States v. Dunn, 269 F. App’x 567, 571 (6th Cir. 2008) (internal quotation marks omitted). These items include a “black assault rifle,” a “dark colored ‘stocking mask,'” a “dark colored Atlanta Braves [b]aseball cap,” a “red hooded pullover,” a “dark shirt,” a “red lanyard,” and “dark colored shoes.” (App’x to Appellant’s Br. at A-4) Accordingly, the warrant—although far from a model of careful drafting—satisfies the particularity requirement of the Fourth Amendment.