LA: Failure to show PC for medical records required suppression

“The district court erred in denying defendant’s motion to suppress despite finding that the officers failed to articulate probable cause in their search warrant application to subpoena defendant’s medical records. A search warrant application must contain within its four corners the facts establishing the existence of probable cause. State v. Duncan, 420 So.2d 1105 (La.1982). Louisiana Code of Evidence article 510 is not an exception to the warrant requirement; rather, it is an exception to the admissibility protections of that evidence after lawful seizure. The evidence in this matter was not lawfully seized; thus, Article 510 does not apply.” State v. Johnson, 2019 La. LEXIS 1360 (April 29, 2019) (per curiam; three dissented on good faith exception).*