M.D.Fla.: 14 years of emails in a complicated tax fraud scheme wasn’t overbroad

Fourteen years worth of emails wasn’t overbroad here. “The case involves a complex tax evasion scheme taking place over many years and across international borders. A wide variety of documents would be relevant to prove this scheme. The warrant in this case, even if it were found to be ‘overly broad,’ is ‘not so facially deficient […] that the executing officers could not have reasonably presumed it to be valid.’ Id. (citing United States v. Accardo, 749 F.2d 1477, 1481 (11th Cir. 1985)).” United States v. Gyetvay, 2022 U.S. Dist. LEXIS 227933 (M.D. Fla. Dec. 19, 2022).

This 2255 claim is based on the warrant issuing judge was also a victim of the crime. Aside from the merits, that’s not a challenge to the voluntariness of his guilty plea. Thibodeau v. Artis, 2022 U.S. App. LEXIS 34942 (6th Cir. Dec. 16, 2022).* [Interesting issue; but would it fail on good faith exception if raised before the plea?]

A valid frisk is the outer clothing, not the pockets. State v. Martin, 2022 Minn. App. LEXIS 160 (Dec. 14, 2022).*

Bailbondsman aren’t state actors under § 1983, and there is no private right of action under the federal kidnapping statute. Hutchins v. Billy Clark Bail Bonds, Inc., 2022 U.S. Dist. LEXIS 227949 (N.D. Fla. Nov. 8, 2022), adopted, 2022 U.S. Dist. LEXIS 227305 (N.D. Fla., Dec. 19, 2022).

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