States v. Pickard, 207 F.2d 472, 475 (9th Cir.1953) (noting that the Warrant Clause secures an individual’s right “to be protected against the issuance of a warrant for his arrest, except ‘upon probable cause supported by oath or affirmation’ ”) (citation omitted); see also Ex Parte Burford, 7 U.S. (3 Cranch) 448, 453, 2 L.Ed. 495 (1806) (“warrant of commitment was illegal, for want of stating some good cause certain, supported by oath ”). In Groh v. Ramirez, 540 U.S. 551, 124 S.Ct. 1284, 157 L.Ed.2d 1068 (2004), the Supreme Court recently affirmed that every warrant must meet the requirements of the Warrant Clause, and be based upon probable cause, supported by oath or affirmation. Id. at 1289-90; see also Albrecht v. United States, 273 U.S. 1, 4-6, 47 S.Ct. 250, 71 L.Ed. 505 (1927) (<HOLDING>). Thus, where a warrant is issued unsupported
holding an arrest warrant invalid because it was issued based upon affidavits which had been sworn to before an official not authorized to administer oaths in federal criminal proceedings holding that in a suit on a sworn account the petition with an attached sworn account and verified affidavit of the sworn account was a liquidated claim proved by written instruments holding that the confrontation clause did not apply to proceedings before a draft board because such proceedings are not stages in a criminal prosecution holding that defendants have a right to counsel in criminal proceedings holding that a written statement could not be regarded as an affidavit sufficient in law for any purpose because it was not sworn to by any one or before any officer