E.D.Mo.: No joint venture shown with Philippines LEOs in seizure of def’s suitcase there

The search in the Philippines was not a joint venture with the United States, so the exclusionary rule doesn’t apply to it. “There is no evidence that the FBI was aware that items from Defendant’s home were in the suitcase. Additionally, the facts directly refute the inference that Filipino law enforcement removed items specific to the FBI investigation at its request. Defendant’s Fourth Amendment rights were not implicated, and his rights were not violated.” United Staes v. McDonald, 2018 U.S. Dist. LEXIS 30223 (E.D. Mo. Feb. 26, 2018).

The search warrant was based on probable cause, and the warrant was limited by the crimes under investigation. Therefore, it was particular. United States v. Rhame, 2018 U.S. Dist. LEXIS 32212 (N.D. Ga. Feb. 28, 2018).*

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