United States v. Brunson, No. 18-4696 (4th Cir. 2020)
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The Fourth Circuit held that the district court did not err in denying defendant's motion to suppress evidence obtained from wiretaps. Defendant argued that because the wiretap orders did not include the name of each authorizing official, the orders were statutorily insufficient and therefore all evidence derived from them should have been suppressed.
The court held that the wiretap orders were sufficient under the Wiretap Act because (1) the applications were in fact appropriately authorized by persons authorized by the Wiretap Act; (2) the orders on their face identified, albeit not by name, the Justice Department officials who authorized the applications; (3) the applications themselves, to which the orders on their face referred, did contain both the title and name of the official authorizing the application; and (4) the applications and proposed orders were submitted together as one package to the judge who signed the orders and later to defendant, whose communications were intercepted, such that both the judge and defendant actually knew both the title and name of the official authorizing each application. Furthermore, even if the court were to assume that the omission of the name of the authorizing official in the orders was a defect, it would not be the type of defect that rendered the orders "insufficient" under Section 2518(10)(a)(ii) of the Wiretap Act.
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