Search Warrants for "All Persons on the Premises"

I have been asked several times about the validity of search warrants that authorize the police to search a particular place and "all persons on the premises." It sounds as though such warrants are most often requested in drug cases. A number of courts across the country have ruled on the validity of these "all persons" warrants, but as far as I know, there are no decisions on point by any North Carolina appellate court. Nationally, a minority of courts have taken the view that "all persons" warrants are always, and inherently, in violation of the Fourth Amendment. See generally United States v. Guadarrama, 128 F. Supp. 2d 1202, 1207 (E.D. Wis. 2001) (collecting cases). These courts believe that "all persons" warrants are too closely akin to the general warrants forbidden by the Fourth Amendment. A substantial majority of courts, however, have taken a more nuanced view. These courts have generally held that such warrants are proper if, and only if, "the facts in the affidavit provide probable cause to believe that anyone in the premises would have on his or her person the evidence that is being sought." Robert L. Farb, Arrest, Search, and Investigation in North Carolina 134 (3rd ed. 2003). The leading case supporting this view is State v. Desimone, 288 A.2d 849 (N.J. 1972). The court there argued: On principle, the sufficiency of a warrant to search persons identified only by their presence at a specified place should depend on the facts. A showing that lottery slips [...]