D.Minn.: Merely asking for a “four corners review” of a search warrant affidavit is not a valid motion to suppress

Merely asking for a “four corners review” of a search warrant affidavit is not a valid motion to suppress. Considering it anyway, there was probable cause. United States v. Reyes, 2013 U.S. Dist. LEXIS 169487 (D. Minn. August 14, 2013):

Defendant makes no specific argument with regard to the legality of the search warrants, but he merely asks for a four-corners review and determination of whether the search warrant was supported by probable cause.

Because the Defendant has identified no specific evidence that he believes should be suppressed, and he has offered no factual or legal grounds for suppression, the Court could recommend denying Defendant’s Motion to Suppress Evidence Obtained as a Result of July 23, 2011 Search and Seizure, [Docket No. 93], solely on the basis that Defendant has failed to meet his burden of production. United States v. Jones, No. 09-cr-260 (DWF/RLE), 2009 U.S. Dist. LEXIS 112286, at *10 (D. Minn. Oct. 30, 2009) (Erickson, C.M.J.) (citing United States v. Mims, 812 F.2d 1068, 1074 (8th Cir. 1987); and United States v. Quiroz, 57 F. Supp. 2d 805, 822-23 (D. Minn. 1999)), adopted by 2009 U.S. Dist. LEXIS 112176 (D. Minn. Dec. 2, 2009) (Frank, J.). “Nonetheless, in an abundance of caution, we proceed with address[ing] the merits of the Defendant’s Motion by considering the probable cause detailed in the [w]arrant’s supporting papers, and by examining for any other fatal deficiencies in the [w]arrant.” Id. (citing United States v. Edwards, 563 F. Supp. 2d 977, 995 (D. Minn. 2008) (Mayeron, M.J.), adopted by 563 F. Supp. 2d 977, 984 (D. Minn. 2008) (Frank, J.).