Whether an administrative warrant used as a subterfuge for criminal investigation violates Fourth Amendment protections and whether reading police reports to a jury over defense objections constitutes reversible error

Kevin Coles was convicted of homicide, drug, and gun charges at trial. He was arrested on an unrelated administrative warrant that was used as a subterfuge to further the criminal investigation in this case. Then, at trial, the Government read seven paragraphs of a police report to the jury over defense objections. Last, Co les was convicted of serious bodily injury related to two drug overdoses where the victims survived and had no lasting injuries. This case is important for review because it concerns the extent to which the Government can utilize administrative warrants in a criminal investigation, whether the Government can read police reports to the jury at trial, and how “bodily injury” should be construed for purposes of the controlled substances statutes. These are important questions to limit government overreach, preserve the safeguards of trial, and to clarify the law with respect to drug overdoses which, sadly, the courts must frequently navigate. The questions presented are: 1. Whether evidence should have been suppressed because the Government improperly used an administrative warrant as a subterfuge to further a criminal investigation? 2. Whether the Government should have been precluded from reading a witness’ interview verbatim to the jury over the Defendant’s objection? 3. Whether judgment of acquittal should have been entered for the “serious bodily injury” components of Counts 14 and 18 where the victims did not sustain serious bodily injury? ii LIST OF ALL