The premises for a search warrant includes the curtilage, and drugs found hidden outside the house on the curtilage just a few feet from the house were properly seized. United States v. Dowling, 2019 U.S. Dist. LEXIS 34956 (D. V.I. Mar. 5, 2019).
Financial records seized by a grand jury subpoena are not subject to suppression under Carpenter.
United States v. Moiseev, 2019 U.S. Dist. LEXIS 34949 (D. Mass. Mar. 5, 2019).*