“[T]he district court did not err in denying Hernandez’s motion to suppress the evidence obtained from the Samsung T199 phone because the search pursuant to the warrant was ‘genuinely independent’ of the initial search. Murray, 487 U.S. at 542.” United States v. Hernandez, 2017 U.S. App. LEXIS 13965 (4th Cir. Aug. 1, 2017).
The officer may not have known the basis for the stop, but the FBI and local police collectively had plenty of probable cause. United States v. Johnson, 2017 U.S. App. LEXIS 14318 (6th Cir. Aug. 1, 2017).*