The government did a cursory warrantless search of two defendants’ cell phones, concerned about a remote wipe, prior to obtaining a search warrant for those phones and others. The independent source rule was satisfied for the searches because there was probable cause and nothing form the prior illegal search of the phones made it into the search warrant applications. United States v. Barron-Soto, 2016 U.S. App. LEXIS 7569 (11th Cir. April 26, 2016).
Texas closely regulates breeder deer under Burger. Anderton v. Tex. Parks & Wildlife Dep’t, 2014 U.S. Dist. LEXIS 185486 (N.D.Tex. Feb. 14, 2014).