W.D.Pa.: Obvious scrivener’s error as to limit of time to execute warrant could be overlooked

A search warrant was issued for defendant’s house, and an obvious scrivener’s error at the time the warrant was issued was entered into the space providing for the latest time when the warrant should be executed. That error could be overlooked where the warrant was executed within three hours of issuance. Also, collective knowledge supported defendant’s stop. United States v. McKay, 2014 U.S. Dist. LEXIS 145985 (W.D. Pa. October 14, 2014).

2255 petitioner’s search and seizure claim was so vague court couldn’t identify it. “Finally, it is not clear which search or seizure Oakgrove is referring to when he indicates that his conviction was obtained through an unconstitutional search and seizure. Without additional information, the Court is unable to analyze the merits of Oakgrove’s claim, and will deny his petition on this ground.” United States v. Oakgrove, 2014 U.S. Dist. LEXIS 146206 (D. Minn. October 14, 2014).*

The search warrant was issued with probable cause, and, even if not, it was close enough that the good faith exception applied. United States v. Shelton, 2014 U.S. Dist. LEXIS 146063 (D. Minn. October 14, 2014),* R&R 2014 U.S. Dist. LEXIS 146367 (D. Minn. August 28, 2014).*