CA9: Overbreadth as to one category in SW moot by fact documents were included in another

In a complex tax avoidance scheme, the IRS obtained search warrant was overbroad as to one category of things to be seized in ¶ u but it was mooted by the fact that items arguably seized under that category were lawfully seized under other parts of the warrant not challenged. United States v. Morton, 2019 U.S. App. LEXIS 17176 (9th Cir. June 7, 2019).*

Defendant’s waiver of forfeiture in his plea agreement denies him standing to seek return of the property. Hurt v. United States, 2019 U.S. Dist. LEXIS 95767 (N.D. Miss. June 7, 2019).*

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