“If a warrant to search a home relies on information from a confidential police informant about contraband inside the home, but the warrant application includes no facts indicating whether the informant could be considered a government agent who violated the resident-defendant’s Fourth Amendment rights, Minnesota Rule of Criminal Procedure 9.01 entitles the defendant to discover non-identifying information relevant to the constitutionality of the informant’s conduct.” (Syllabus) State v. Dexter, 2019 Minn. App. LEXIS 185 (May 20, 2019).
“Rather, [defendant] only argues that the Fourth Amendment demands that evidence from warrantless searches not falling under an exception to the warrant requirement usually be excluded …. His arguments have no bearing on the question posed in this case, however. Because the initial buccal swab was not precluded by controlling precedent at the time, suppression of the evidence would not have been required even if the swab had been illegally obtained.” Davis v. United States, 2019 U.S. Dist. LEXIS 85349 (E.D. Tenn. May 21, 2019).*