This case started with an anonymous letter about alleged drug sales at defendant’s residence. A trash pull was conducted on “Thursday.” Read in context, that means the previous Thursday, and the search warrant wasn’t stale when issued. State v. Teague, 2018 N.C. App. LEXIS 525 (June 5, 2018). They use the Naval Observatory to determine that a particular date was a Thursday. Why couldn’t they just look at the calendar on their phone? Calendars are never not subject to judicial notice.
“Contrary to Ardoin’s arguments, the affidavit supporting the first warrant is not bare bones. It contained facts and circumstances within the personal knowledge of the affiant rather than ‘wholly conclusory statements.’” And, the good faith exception applies. United States v. Ardoin, 2018 U.S. App. LEXIS 15067 (5th Cir. June 5, 2018).*