Nexus was shown to defendant’s cell phone because the affidavit in support of the search warrant for the phone showed that the gang had used cell phones to communicate and defendant was using his phone when arrested and he’d already been indicted in the RICO conspiracy. In any event, the good faith exception applies. United States v. Johnson, 2018 U.S. App. LEXIS 5346 (6th Cir. Mar. 2, 2018).
There was probable cause for the state search warrant based on the CI’s story that the police investigated and proved accurate. United States v. Davis, 2018 U.S. Dist. LEXIS 31819 (E.D. Mo. Feb. 28, 2018).*