“Here, the agent articulated several observations which, based on his eight years of experience at this [immigration] checkpoint, indicated that the truck’s spare tire contained contraband. Viewing this testimony in the light most favorable to the Government, and giving due deference to the district court’s assessment of the evidence, the court finds that Agent Carriaga had probable cause to believe the truck contained contraband before he ‘smacked’ the spare tire. Therefore, even if the ‘smack’ was a search, it did not violate the Fourth Amendment.” United States v. Martinez, 2017 U.S. App. LEXIS 18586 (5th Cir. Sept. 26, 2017).
“Assuming without deciding that the search warrants lacked probable cause, the Court concludes that the evidence is nonetheless admissible under the good-faith exception to the exclusionary rule as articulated in United States v. Leon, …,” United States v. Forthun, 2017 U.S. Dist. LEXIS 159410 (D. Minn. Sept. 8, 2017),* adopted in part and modified in part, 2017 U.S. Dist. LEXIS 156744 (D. Minn. Sept. 25, 2017).*