Defendant’s cell phone was properly seized incident to his arrest, as contemplated by Riley. It was not searched until a search warrant was obtained. State v. Wade, 2018 Tenn. Crim. App. LEXIS 523 (July 13, 2018).
The search warrant for defendant’s residence for evidence of sex trafficking was not stale. Some of the information developed was six years old, showing it was ongoing. He was alleged to be a “house boss” working from home, and that provided nexus to his house. United States v. Morris, 2018 U.S. Dist. LEXIS 115299 (D. Minn. July 11, 2018).*