Defendant’s cell phone was seized by consent and a search warrant was obtained for it. It took nine months for the search to occur. Because nothing changed between the seizure, the warrant, and the search, the ultimate search was not unreasonable. Commonwealth v. Knoble, 2018 PA Super 135 (May 24, 2018).
Defendant’s appeal waiver provision in the plea agreement waived his claim that the district court should have sua sponte suppressed evidence without a motion to suppress. United States v. Bass, 2018 U.S. App. LEXIS 13698 (8th Cir. May 24, 2018).*