The exclusionary rule does not apply to searches leading to revocation of federal supervised release. United States v. Tran, 2019 U.S. Dist. LEXIS 32836 (D. Kan. Mar. 1, 2019).
“Defendant speculates, based on information in a search warrant application, that the grand jury may have heard prejudicial information regarding gang activity. This claim is plainly insufficient to warrant intrusion into grand jury proceedings. Thus, defendant’s request for disclosure or Court review of grand jury material is denied.” United States v. Watkins, 2019 U.S. Dist. LEXIS 31460 (W.D. N.Y. Jan. 18, 2019),* adopted, 2019 U.S. Dist. LEXIS 30482 (W.D. N.Y. Feb. 26, 2019).*