In re Search Warrants re Seizure of Docs.

Summary

The court affirmed the denial of the motions to quash and unseal the search warrants because the warrant materials established probable cause and the ongoing investigation supplied good cause to keep them sealed. It reversed the denial of the return-of-property motion because the district court did not allow the businesses access to seized materials or an opportunity to establish privilege before permitting law enforcement to review them. The court held that Nevada's return-of-property statute permits relief for privileged materials even during an ongoing investigation and requires a privilege process that prevents unilateral disclosure by law enforcement.