The following excerpt is from United States v. Smith, 967 F.3d 198 (2nd Cir. 2020):
Other courts have well explained why the police may not unreasonably delay in seeking a warrant. "We demand expediency in obtaining a search warrant to search seized evidence in order to avoid interfering with a continuing possessory interest for longer than reasonably necessary, in case the search reveals no evidence (or permissibly segregable evidence) of a crime and the item has no independent evidentiary value and is not otherwise forfeitable." United States v. Sparks , 806 F.3d 1323, 1340 (11th Cir. 2015). Moreover, "unnecessary delays also undermine the criminal justice process in a more general way: they prevent the judiciary from promptly evaluating and correcting improper seizures."
[967 F.3d 206]
United States v. Burgard , 675 F.3d 1029, 1033 (7th Cir. 2012). "What, after all, is reasonable about police seizing an individual's property on the ground that it potentially contains relevant evidence and then simply neglecting for months or years to search that property to determine whether it really does hold relevant evidence needed for trial or is totally irrelevant to the investigation and should be returned to its rightful owner?" United States v. Christie , 717 F.3d 1156, 1162 (10th Cir. 2013) (Gorsuch, J .).
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