DC: A SW doesn’t have to be just for evidence of a crime—it can be for “evidence that might lead to other evidence”

A search warrant doesn’t have to be just for evidence of a crime—it can be for “evidence that might lead to other evidence.” In re Grand Jury Witness G.B., 2016 D.C. App. LEXIS 170 (May 26, 2016):

There is no reason to think that the drafters of Rule 41 had in mind the much more cramped notion of “evidence of a criminal offense” G.B. advocates. We conclude that Rule 41 (b)’s reference to “evidence of the commission of a criminal offense” includes within its scope “evidence that might lead to other evidence.” Further, our case law establishes that if there is reason to believe that the evidence sought will aid in apprehending or convicting a criminal, a warrant to obtain it may properly issue, even if it is expected that the evidence will be corroborative of evidence law enforcement officials already have. See Rutledge v. United States, 283 A.2d 213, 215-16 (D.C. 1971) (holding that a warrant was properly issued to search for hashish in appellant’s apartment because the presence of the drug would corroborate an informant’s testimony that appellant was an “illegal transferor of that narcotic,” notwithstanding appellant’s objection that “the presence of hashish in his apartment would not prove that he had transferred it in the past or that he was selling it when the warrant was executed”).