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Sean Combs’s Lawyers Challenged Evidence From Four Search Warrants

Combs’s lawyers sought to suppress evidence from four 2024 warrants, challenging warrant applications and search scope. A federal judge denied the motion on May 9, 2025.
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Sean Combs’s lawyers asked a federal judge to suppress evidence obtained under four 2024 search warrants, arguing that the warrant applications were misleading and the warrants too broad. U.S. District Judge Arun Subramanian denied the motion on May 9, 2025. The ruling addressed the legality of the searches and the request to exclude evidence; it was not a determination of guilt or a resolution of every factual allegation in the criminal case.

What the motion challenged

The defense memorandum identified four warrants issued in 2024. They covered Combs’s iCloud accounts, his residences in Los Angeles and Miami, and a search of his person and two cell phones. The dates and targets described in the filing were:

  • January 4, 2024: information in Combs’s iCloud accounts.
  • March 22, 2024: his Los Angeles and Miami residences.
  • March 25, 2024: Combs’s person and two cell phones.

The defense sought to suppress evidence obtained through the warrants or, alternatively, to obtain a Franks evidentiary hearing. Its memorandum is an advocacy filing: the claims in it should not be read as findings by the court. Read the defense memorandum.

What Combs’s lawyers argued

Alleged false statements and omissions

The defense argued that the warrant applications included statements that were intentionally or recklessly deceptive, and left out information it said was important. Among its claims were that the applications omitted information about witness credibility and evidence Combs characterized as exculpatory. These were defense allegations, not judicial findings that investigators had misled the court.

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Scope of the searches

The defense also argued that the warrants were unconstitutionally broad, particularly in their authorization to search digital devices and accounts. This challenged the scope and specificity of the searches, separate from the argument that the applications contained misleading statements or omissions.

How the judge assessed the challenge

In his May 9, 2025 opinion, Judge Subramanian explained that a request for a Franks hearing requires a preliminary showing of both a relevant state of mind and materiality. The defendant must make a substantial preliminary showing that an affiant deliberately included a false statement or acted with reckless disregard for the truth. The challenged statement or omission must also matter to probable cause.

To assess materiality, the opinion describes a practical test: remove the alleged falsehoods and account for the alleged omissions, then ask whether the warrant application still supports probable cause. The court concluded that the alleged misstatements and omissions were not material to that determination and that Combs had not made the required preliminary showing of intentional or reckless deception for a Franks hearing.

Particularity and breadth

The judge considered the warrant-scope challenge separately and concluded that the warrants were sufficiently particularized. That ruling rejected the defense’s request to suppress evidence on the grounds raised in this motion; it does not establish that every underlying allegation in the prosecution is true or settle issues beyond the warrant challenge.

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The ruling

Judge Subramanian denied the motion to suppress on May 9, 2025. The opinion states: “For the following reasons, the motion to suppress is DENIED.” Read the Opinion and Order.

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