FL: Search that violated statute but not Fourth Amendment not suppressed

Violation of state strip search statute did not warrant suppression because the search was valid under the Fourth Amendment. Rumore v. State, 969 So. 2d 551 (Fla. 2d DCA 2007):

Furthermore, we hold that the subsequent strip search of Mr. Rumore’s person was reasonable under the Fourth Amendment but unlawful under Crawford v. State, 980 So. 2d 521 (Fla. 2d DCA 2007).*

A search warrant was not invalid for not mentioning that defendants lived there. United States v. Xiong, 2007 U.S. Dist. LEXIS 87085 (E.D. Wis. November 26, 2007):

An accurate street address is by itself sufficient to allow a reasonable person to “ascertain and identify the place intended.” Id. Here, the warrant included in addition to an accurate street address, a physical description of the premises. Defendants have offered no explanation of why this was not sufficient.

Inevitable discovery supported seizure of 10,000 pounds of marijuana from defendant’s house which they could smell after the door was opened. They did a “protective sweep” and sent for a warrant. The inevitable discovery doctrine supported the seizure. Herrera-Fernandez v. State, 2007 Fla. App. LEXIS 18729 (Fla. 4th DCA November 28, 2007).*