Grand jury subpoenas are a proper method of obtaining bank records under the Right to Financial Privacy Act enacted after Miller. Also, suppression and dismissal aren’t remedies under the Act. United States v. Lundahl, 2021 U.S. Dist. LEXIS 52211 (D.S.D. Mar. 19, 2021).
The inventory of defendant’s vehicle was reasonable because he lacked a driver’s license, it wasn’t insured, and it lacked a license plate. United States v. Riley, 2021 U.S. Dist. LEXIS 52029 (E.D. Mich. Mar. 19, 2021).*
Defendant’s claim there was a Franks violation in the statement that the drug dog never had a false alert fails for lack of materiality. Without that statement, there still is probable cause. United States v. Wofford, 2021 U.S. Dist. LEXIS 52052 (W.D. N.Y. Mar. 19, 2021).*