Does a search warrant need to include an incorporated, unattached supporting document that does not reference criminal statutes?

MultiRegion, United States of America

The following excerpt is from United States v. Romain, No. 15-3404 (2nd Cir. 2017):

U.S. 551, 557 (2004), and "unincorporated, unattached supporting documents [do not] cure an otherwise defective search warrant," United States v. Rosa, 626 F.3d 56, 64 (2d Cir. 2010). Here, the government concedes that the warrant was facially deficient for failing to reference the criminal statutes that Romain was accused of violating even though the supporting documents did contain that information.

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