CT: City housing admin SW was properly issued; no state constitutional right to adversary proceeding first

City inspectors suspected defendant’s premises to have an illegal third apartment because there were three mailboxes and entrances and other suspicions. He refused an inspection by city officials, so they applied for an administrative search warrant that showed probable cause to believe the city ordinances were being violated. City inspectors went with police as backup, and they found bomb making equipment in plain view. That resulted in a second search warrant for evidence of crime, and this produced more evidence of a bomb and child pornography. First, defendant didn’t preserve his claim that the judge who issued that administrative search warrant lacked authority, but it would fail on the merits anyway because he did. Second, there was probable cause for the administrative search warrant based on three mailboxes and three entrances. Third, the state constitutional claim that a search warrant couldn’t be issued ex parte loses because there’s no reason for a different state rule. Fourth, breaking a lock to enter was not an unreasonable search. State v. Saturno, 2016 Conn. LEXIS 198 (July 19, 2016).

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