United States v. Bradley
United States Court of Appeals for the Eleventh Circuit
644 F.3d 1213 (11th Cir. 2011)
Law enforcement executed a search warrant on Bio-Med (defendant), seizing all business files spanning multiple years, based on an affidavit alleging fraud that spread to Bio-Med's principals, officers, suppliers, and various other business partners; Bio-Med moved to suppress the seized evidence as overly broad, arguing the underlying fraud represented only a small percentage of its overall business, but the district court denied the motion and Bio-Med appealed.
Whether a broad search warrant seizing a company's records across multiple years and business areas is justified under the pervasive fraud doctrine when the fraud at issue represents only a small percentage of the company's overall business.