The warrantless search of defendant’s apartment, his person, and his cell phone was justified by exigent circumstances under the Fourth Amendment because the still-missing kidnapping victim’s life was in danger. The police reasonably believed that his phone had been used in the kidnapping operation. State v. Buck, 2017-Ohio-8242, 2017 Ohio App. LEXIS 4619 (1st Dist. Oct. 20, 2017).
A truck with about 50-60 undocumented persons getting out of it was seen in a parking lot in Albuquerque but police were only able to round up about 15 of them. They were disoriented and didn’t know where they were. It was obvious they were treated as cargo in the back of the truck. Defendant was connected to the truck. A protective sweep of his house was reasonable. That resulted in a valid search warrant. United States v. Mora, 2017 U.S. Dist. LEXIS 171532 (D. N.M. Oct. 17, 2017).*