Does the Exclusionary Rule Apply? - Trinity Industries v. OSHA, 16 F.3d 1455 (6th Cir. 1994)
OSHA used an employee complaint as the basis for a probable cause warrant for a specific inspection, as provided in the OSHA Act.
Inspector also did a general search, claiming it was part of an area warrant type search
Court found that a complaint driven search does not meet the neutral selection criteria for an area warrant
Court allowed the use of the improperly obtained records for administrative actions to correct risks, but not as a basis for punishing (fining) the employer