D.Ore.: Detailed extra information to provide context that ultimately proves unnecessary to the PC finding doesn’t make the warrant bad

“SA Nix’s 56-page affidavit provides detailed information that is directly connected to an evasion of payment charge. Those few sentences or portions of sentences that pertain exclusively to an evasion of tax assessment charge have a de minimis impact on the scope of the warrant. Adopting Defendant’s argument would put this Court in the untenable position of having to suppress evidence every time an affidavit includes information not directly relevant to the charge at issue. This Court sees no reason to constrain a law enforcement affiant from providing additional contextual information especially in complex financial crimes cases.” United States v. Millegan, 2022 U.S. Dist. LEXIS 54722 (D.Ore. Mar. 25, 2022).*

Defendant’s admission in a jail call that the methamphetamine in the case was his led to a search warrant for his cell phone. Henderson v. United States, 2022 U.S. Dist. LEXIS 54617 (W.D.N.C. Mar. 25, 2022).*

There were disputes in the facts to deny qualified immunity and require a trial. Was decedent posing a threat or not when he was shot? Estate of Aguirre v. Cnty. of Riverside, 2022 U.S. App. LEXIS 7925 (9th Cir. Mar. 24, 2022).*