United States v. Mark Edwin Sells

EBEL, Circuit Judge.

Under the severability doctrine, “[t]he infirmity of part of a warrant requires the suppression of evidence seized pursuant to that part of the warrant, but does not require the suppression of anything described in the valid portions of the warrant (or lawfully seized — on plain view grounds, for example — during ... execution [of the valid portions]).” United, States v. Brown, 984 F.2d 1074, 1077 (10th Cir.1993) (quotations, alteration omitted). We adopted the doctrine in Brown, and more fully addressed it in United States v. Naugle, 997 F.2d 819, 822-23 (10th Cir.1993);…