E.D.Wis.: Facebook SW had thin but sufficient showing of PC, and GFE applied

The police had information that armed robbers were communicating on Facebook about their plans. The affidavit of probable cause as to this defendant’s Facebook account was thin, but it was similar to that of the other defendants and it still barely showed probable cause. And it was not so bare bones that the good faith exception should apply. United States v. Chambers, 2016 U.S. Dist. LEXIS 149047 (E.D. Wis. Sept. 14, 2016),* adopted, 2016 U.S. Dist. LEXIS 149050 (E.D. Wis. Oct. 26, 2016).*

Assuming the police entry into defendant’s apartment was unlawful, the later search warrant was fully based on other information which showed probable cause and this was a valid independent source. United States v. Mack, 2016 U.S. App. LEXIS 19900 (11th Cir. Nov. 4, 2016).*

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