E.D.Mich.: Health care fraud SW also reached def’s home because related mail was received there

In a health care fraud case, the fact some mail within the scheme came to defendant’s home was nexus for the search warrant including the home. “All of the items identified in the indictment were tied to or related to potential instruments of Defendants’ alleged health care fraud scheme. The search warrants did not violate the particularity requirement of the Fourth Amendment. [¶] The affidavit also sufficiently establishes a nexus to search the Defendants’ residence. The affidavit provided evidence that Defendants brought work related materials to their home and that they received work related materials through the mail at their home. Defendants fail to demonstrate that probable cause was lacking to conduct the search of their home. [¶] Finally, contrary to Defendants’ arguments here, the search warrant affidavit at issue is supported by more than mere suspicions or beliefs, and does in fact contain the underlying factual circumstances of Defendants’ criminal activity. The affidavit cannot be characterized as a ‘bare bones’ affidavit.” United States v. Barnwal, 2019 U.S. Dist. LEXIS 57181 (E.D. Mich. Apr. 3, 2019).*