D.Md.: Blanket suppression reserved for flagrant cases; this isn’t

The search warrant didn’t specify that cash was subject to seizure, but it reasonably falls within evidence of the subject matter of the search warrant. To exclude the cash would be a “hypertechnical” suppression argument. Moreover, blanket suppression is reserved for flagrant cases. United States v. Kimble, 2015 U.S. Dist. LEXIS 90107 (D.Md. July 8, 2015):

“Blanket suppression” of evidence may be appropriate when “officers flagrantly disregard the terms of the warrant” or “engage in a fishing expedition for the discovery of incriminating evidence.” [United States v. Uzenski, 434 F. 3d 690, 706 (4th Cir. 2006) (quoting United States v. Foster, 100 F.3d 846, 849-50 (10th Cir. 1996))] (internal quotation marks and citations omitted). However, blanket suppression is an “extraordinary remedy that should be used only when the violations of the warrant’s requirements are so extreme that the search is essentially transformed into an impermissible general search.” Id. (quoting Robinson, 275 F.3d at 381).