The following excerpt is from U.S. v. Webb, 890 F.2d 420 (9th Cir. 1989):
Webb next challenges the validity of the search warrant, contending that it was unconstitutionally overbroad. The question of whether a warrant is unconstitutionally overbroad is a question of law which we review de novo. United States v. Perdomo, 800 F.2d 916, 920 (9th Cir.1986).
Webb argues that the general language at the end of the warrant, authorizing seizure of "Records of drug sales and income," was overbroad because it allowed seizure of all records of income, regardless of their relationship to drug transactions. This court has held that "general language located at the end of a warrant is to be viewed as relating only to the specific offense named in preceding portions of the warrant." Id. (construing Andreson v. Maryland, 427 U.S. 463, 479-82 (1976). Here, the general reference to "income" at the end of the warrant is read as it relates to the crimes specified in the warrant: marijuana cultivation, processing and distribution. Thus, the warrant is not overbroad as to its scope.
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