D.Md.: Fact the SW sought drugs necessarily permits a detailed search of small places; doesn’t make it a general warrant

The fact the search warrant sought drugs necessarily permits a detailed search of small places, but that doesn’t make it a general warrant. The good faith exception applies, too. United States v. Minnick, 2016 U.S. Dist. LEXIS 80897 (D.Md. June 21, 2016):

The warrant admittedly covered many types of items and would necessitate a search of all or most of the premises because some items, such as drugs, records relating to drug dealing, and drug proceeds could be hidden in very small areas. But items could only be seized if they in some way related to those offenses. Cf. Williams, 592 F.3d at 520 (noting that even though the authorized search necessarily required review of “a large collection of items,” the warrant limited the search and seizure of material on computer systems and digital storage media to information relating to specific state law offenses of harassment by computer or threats against others). The paperwork, photographs, and jewelry seized during the search met that requirement, either as evidence of drug dealing or likely proceeds of drug dealing. The Court therefore rejects the argument that this was a general warrant.

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