Defendant’s car was subject to the automobile exception even though it was parked on private property. Waiting 28 days to get a search warrant for cell phones made the search unreasonable. United States v. Civil, 2017 U.S. Dist. LEXIS 158377 (N.D. Fla. Aug. 1, 2017).
The government proved consent on the totality of the circumstances. United States v. Dickinson, 2017 U.S. Dist. LEXIS 156578 (E.D. N.C. Aug. 21, 2017).*