The following excerpt is from U.S. v. Chen, 979 F.2d 714 (9th Cir. 1992):
The district court also considered the fact that the warrants allegedly contained no limit on the number of surreptitious entries. This is not an error by the agents in complying with the terms of the warrant and does not support a flagrant disregard finding. There is no requirement that the warrant include a "specific authorization to enter covertly the premises described in the order." Dalia v. United States, 441 U.S. 238, 258-59, 99 S.Ct. 1682, 1694, 60 L.Ed.2d 177 (1979) (footnote omitted). This does not mean that agents can ignore the rights of others. The agents must limit their entry in a reasonable manner. Id. at 258, 99 S.Ct. at 1693. But, the district judge relied solely on the lack of sufficient limitations in the warrant, which he could not do to support a flagrant disregard finding.
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