D.Me.: CP on a cell phone is nexus to CP being on a computer

Child pornography on defendant’s cell phone is nexus to his computer. Computers are common storage devices for cell phone pictures and information. “Common sense suggests that if an individual has images of child pornography downloaded to one electronic device, the individual likely has similar, if not the same, images on other electronic devices the individual possesses. The state court judge, however, did not have to rely solely upon his own common sense to find probable cause.” United States v. Jack, 2017 U.S. Dist. LEXIS 172135 (D. Me. Oct. 18, 2017), adopted, 2017 U.S. Dist. LEXIS 198761 (D. Me. Dec. 4, 2017).

The officer who stopped defendant knew from other officers that he was a suspect in drug dealing, and that informed his information gathering during the stop that rose to reasonable suspicion to extend the stop. United States v. Quintero-Bernal, 2017 U.S. Dist. LEXIS 201986 (S.D. Cal. Dec. 7, 2017).*