D.Minn.: If there are enough “thorny issues” on validity of warrant, just turn to GFE [should have said: “close enough for government work”]

“But in this case, it is unclear whether other documents [the attachments]—in addition to the one page List of Items to Be Seized—accompanied the search warrant. In other words, it is impossible to tell, in this four-corners review, whether Subsection b was originally a second page to the list of items to be seized or whether the affidavit accompanied the warrant. … [¶] Here, as was the case in Hamilton, ‘there are enough thorny issues to convince [the court] to avoid deciding the issue.’ Id. at 1027 (concluding that even if the warrant failed to meet the particularity requirement, imposition of the exclusionary rule was not supported). Accordingly, this Court need not decide whether the warrant was sufficiently particularized or whether the affidavit was adequately referenced or attached for incorporation because the good-faith exception applies.” United States v. Karkalas, 2016 U.S. Dist. LEXIS 60153 (D.Minn. Feb. 1, 2016), adopted 2016 U.S. Dist. LEXIS 59368 (D. Minn. May 3, 2016).

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