The totality of the circumstances showed a logical nexus among burglaries, defendant’s vehicle, and defendant for placement of a GPS by court order. There was a sufficient basis for finding probable cause that defendant was the person who committed the burglaries. Defendant’s claim that the GPS couldn’t be monitored when the vehicle was in another state wasn’t preserved at the trial court. Lewis v. State, 2018 Del. LEXIS 48 (Jan. 30, 2018).
The search of defendant’s trash was properly considered in issuing the search warrant for the house. Guardarrama v. State, 2018 Del. LEXIS 49 (Jan. 30, 2018) (memorandum).*