N.D.Ill.: PO seeing an “unregistered” cell phone was seizure in plain view

Defendant was on supervised release for child pornography and he had a cell phone not listed with US Probation. The phone was seen during a home visit. The PO picked up the phone and turned it on and a picture of a young child appeared. The phone was seized because of the plain view and it was a valid seizure. United States v. McGill, 2017 U.S. Dist. LEXIS 184535 (N.D.Ill. Nov. 7, 2017).

Just because there’s an inconsistency between the two officers in their reports, that’s not enough to justify a hearing. The reports show that the officers had reasonable suspicion for the stop. United States v. Bass, 2017 U.S. Dist. LEXIS 186942 (N.D. Ill. Nov. 13, 2017).*

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