ID: Search of second two cell phones just prior to warrant issuing was inevitable discovery

Defendant had three cell phones and the police had a search warrant for one based on its location because defendant’s rape victim said she believed there was a video of her on the phone. When the others were discovered, other search warrants were obtained. It wasn’t appropriate to search them before the search warrant arrived, but inevitable discovery applies. State v. Russo, 2014 Ida. LEXIS 194 (July 31, 2014).*

The affidavit for the search warrant for this private airplane after it landed in Texas was close and just barely more than bare bones. Therefore, the good faith exception would be applied. United States v. Massi, 2014 U.S. App. LEXIS 14815 (5th Cir. August 1, 2014)* (2-1) [To me, this was not more than bare bones. It was a real stretch to get to reasonable suspicion, let alone probable cause, which is still not enough to get a search warrant.]

Touching defendant in a crowded and noisy bar to navigate away from the crowd didn’t turn a consensual encounter into a seizure. United States v. Jackson, 2014 U.S. App. LEXIS 14646 (3d Cir. July 31, 2014).*