CA2: Car not named in SW could be seized and searched incident to forfeiture

The warrant here was for defendant’s house and grounds. No vehicles were mentioned even though officers had knowledge defendant dealt drugs at least from one. On executing the warrant, they found the vehicle and seized it for forfeiture. Searching it later, they found drugs and a gun. The seizure and search were reasonable. United States v. Acevedo, 2026 U.S. App. LEXIS 30220 (2d Cir. Oct. 2, 2026), distinguishing United States v. Lasanta, 978 F.2d 1300 (2d Cir. 1992), with different facts.

Controlled buys and surveillance led to probable cause for defendant’s house for evidence of drug sales. United States v. Brown, 2026 U.S. Dist. LEXIS 225680 (E.D. Pa. Oct. 1, 2026).*

Defendant’s house and RV parked outside where he sometimes stayed were both his residence for purposes of his probation search condition. United States v. Brown, 2026 U.S. Dist. LEXIS 225857 (D. Mont. Oct. 1, 2026).*

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