D.Minn.: Seeking “four corners review” of affidavit for SW isn’t a proper motion to suppress

A generalized motion to suppress merely seeking “four corners review” of probable cause is insufficient. “Defendant’s failure to specify the basis for his suppression motion and provide any argument in support thereof warrants denial alone.” “Defendant’s motion also fails because there was ample probable cause to issue the Search Warrant.” United States v. Berglund, 2021 U.S. Dist. LEXIS 14074 (D. Minn. Jan. 7, 2021), adopted, United States v. Berglund, 2021 U.S. Dist. LEXIS 13249 (D. Minn. Jan. 25, 2021).

“Here, a common sense reading of the warrant and affidavit shows facts establishing a firm probability that evidence of drug use and distribution would be found at Mr. Richmond’s residence. The affidavit, which was written under oath, stated that the CI had personally witnessed Defendant distribute methamphetamine in the Fulton, Missouri area and had seen methamphetamine inside of Mr. Richmond’s apartment on multiple occasions, including at least once 72 hours before the search warrant was obtained.” Alternatively, the good faith exception applies. United States v. Richmond, 2020 U.S. Dist. LEXIS 248553 (W.D. Mo. Dec. 15, 2020),* adopted, 2021 U.S. Dist. LEXIS 13815 (W.D. Mo. Jan. 25, 2021).*