An “all record” warrant for patient records had a sufficient showing, and it was not overbroad. “The Government is not required to have evidence relating to each and every patient in order to justify the seizure of all patient files.” The government showed the practice was “permeated” by fraud. And, the good faith exception applies. United States v. Minhas, 2016 U.S. Dist. LEXIS 13061 (E.D.Mich. Feb. 3, 2016).
An anonymous tip justified a stop about defendant’s vehicle when the LPN told the officers that the vehicle was stolen and the occupants were armed and dangerous. That was reasonable suspicion. United States v. Foster, 2016 U.S. Dist. LEXIS 12672 (D.Del. Feb. 3, 2016).*
The affiant’s mistake that the cell phone company in a ping order was headquarted in Nebraska when it was in Kansas was not material for Franks purposes. United States v. Zelazny, 2016 U.S. Dist. LEXIS 13513 (D.Neb. Jan. 7, 2016), adopted 2016 U.S. Dist. LEXIS 13516 (D.Neb. Feb. 4, 2016).*