N.D.Ga.: SW for evidence of a robbery in a hotel room revealed evidence of identity theft, and it could be seized

In executing a search warrant for two hotel rooms for evidence of armed robbery occurring there, the officers encountered obvious evidence of identity theft in plain view, and it could be seized. “[W]hen they entered the room, he observed a bunch of financial documents with different names and folders with different names on the folders, hundreds of debit and credit cards with different names and some blank cards, and lots of information from tax refund cards in different names. Based on his observations, he believed the items to be evidence of fraudulent criminal activity because the location was a residence not a business. … Detective Barnes’ testimony did not clarify where all of this evidence was located, but he stated that, when searching for evidence of robbery, shells and casings are located in surprising places and that blood goes ‘crazy’ places.” United States v. Rives, 2015 U.S. Dist. LEXIS 159708 (N.D. Ga. Sept. 15, 2015).