W.D.Pa.: Address particular enough for SW

A search warrant for an address is particular enough. Defendant challenged it in the suppression hearing without any citation of authority, and thus essentially waived the argument, but would lose on the merits anyway. There was also probable cause to connect the address to the robbery as a place where evidence would likely be found. United States v. Harris, 884 F. Supp. 2d 383 (W.D. Pa. 2012).

The FTCA does not apply to discretionary government functions, like the decision to investigate, but it does apply to illegal searches conducted after the decision to investigate. Muhammad v. United States, 2012 U.S. Dist. LEXIS 110617 (E.D. Pa. August 6, 2012).

“Finally, Movants’ argument that the subpoenas violate the Fourth Amendment lacks merit. In United States v. Miller, 425 U.S. 435, 442-443 (1967), the Supreme Court held that bank customers have no legitimate expectation of privacy in their bank records. Therefore, when a federal agency issues a subpoena for customer records from a bank, the customer cannot successfully challenge the subpoena on Fourth Amendment grounds. Id.” Tabet v. United States SEC, 2012 U.S. Dist. LEXIS 110048 (S.D. Cal. August 6, 2012).*