The Secretary of Labor’s administrative subpoena duces tecum here did not violate the Fourth Amendment. “A warrant is required only when government officials enter onto a private party’s premises without consent and forcibly take possession of documents.” Walsh v. Int’l Union, Local No. 18, 2021 U.S. Dist. LEXIS 250148 (C.D.Cal. Nov. 23, 2021).
The officer developed reasonable suspicion for further detention before he said “good to go.” Once he had it, he didn’t need additional reasonable suspicion after that to extend the stop. People v. Gamboa-Jimenez, 2022COA10, 2022 Colo. App. LEXIS 72 (Jan. 13, 2022).
A nine month delay to search a seized computer was not unreasonable. United States v. Baker, 2022 U.S. Dist. LEXIS 6416 (W.D.N.Y. Jan. 12, 2022).*