Defendant’s cell phone was properly seized incident to his arrest. It was later searched with “search warrant 1.” When the defense filed a motion to suppress, the government got “search warrant 2” which was legally sufficient. United States v. Bailey, 2018 U.S. Dist. LEXIS 78445 (E.D. Mich. May 9, 2018).
The affidavit showed reason for crediting the CI’s statement. “Assuming arguendo that one of the statements [for the search warrant] was false, the Defendant has failed to show that any misstatement was made intentionally or with reckless disregard for the truth.” United States v. Alvarez, 2018 U.S. Dist. LEXIS 76849 (W.D. Tex. May 7, 2018).*