D.Ore.: Second cell phone search warrant 29 mo after first was not unreasonable

The first search warrant for defendant’s phones was valid, and the government could have still used the phones as evidence. But, 29 months later, the government sought a second search warrant to look at the phone again, and found more information. The second search warrant was not unlawful, and the government was retaining possession of the cell phones anyway. United States v. Rodriguez, 2015 U.S. Dist. LEXIS 15038 (D.Ore. February 6, 2015).*

The reference to CIs in the affidavit for search warrants was only a part of the whole, and whether the CI was adequately corroborated fails under the good faith exception on the affidavit as a whole. United States v. Riley, 2015 U.S. Dist. LEXIS 15332 (D.Md. February 4, 2015).*

The 2255 is denied because petitioner can’t show that he was prejudiced by defense counsel not challenging a consent search that would clearly lose because defendant’s wife consented. United States v. Bass, 2015 U.S. Dist. LEXIS 13808 (D.Colo. February 4, 2015).*