UNITED STATES OF AMERICA v. KAREN KIMBLE
US Court of Appeals for the Fourth Circuit, Wynn, May 2, 2017,
Search Warrant- Evidence seized during a search warrant need only be potentially evidentiary (not obviously/definitely related)

Facts:
Kimble participated in a fraudulent marriage/immigration scheme with a native of Ghana and perjured herself in his brother’s heroin importation trial.
The Department of Homeland Security (DHS) then obtained a search warrant related to the immigration fraud/perjury and located $41,000 in cash found in a bag in a laundry basket. Kimble initially stated that the money wasn’t hers and that she was holding it for a drug trafficker; DHS seized the money believing it was related to drug trafficking. Kimble then filed a claim to recover the money, claiming on the form that it was hers and that the money was from an insurance claim.
After Kimble’s bank records were subpoenaed, she was charged with submitting numerous fraudulent tax returns (keeping over $200,000 in inflated refunds).
At trial, Kimble moved to suppress the cash found in the initial search warrant, claiming that it was improperly seized.

Law:
Holding: Because the cash could have been the proceeds of her immigration fraud scheme, DHS was not wrong to seize it.

Search Warrant – A search warrant limits the extent of the search by explaining what law-enforcement can look for.

Search and Seizure Warrant – Items seized during a search & seizure warrant only have to be potential evidence (they don’t have to obviously be evidence)