A DEA administrative subpoena to a doctor’s office was overbroad where it sought all patient records for 41 patients. The doctor’s objection is sustained. The subpoena needs to be narrower in scope to match that of the investigation. United States v. Wilson, 2022 U.S. Dist. LEXIS 210318 (D.N.M. Nov. 21, 2022).
Defendant’s acquiring a pill making machine that was moved from place to place wasn’t enough to show probable cause for his house. They had no information at all that defendant made pills at his house. The affidavit was thus so lacking in probable cause that the good faith exception did not apply. United States v. Dauphinais, 2022 U.S. Dist. LEXIS 209876 (E.D. Mich. Nov. 18, 2022).*
“The Magistrate Judge had a substantial basis here for finding probable cause. The search warrant application provided a detailed description of the cooperating witness’s personal experience purchasing methamphetamine at the Home. [citing Gates]” United States v. Laury, 2022 U.S. App. LEXIS 32025 (3d Cir. Nov. 21, 2022).*