N.D.Ill.: Cell phone SW in white collar case also for proof of perjury was a virtual computer search but it was still one issued on PC

In an investigation into job promotion and hiring fraud in the Cook County Circuit Clerk’s office, a cell phone search warrant was issued, and it was with probable cause. “Because the affidavit established probable cause to believe that Beena’s cell phone contained evidence of a crime, specifically evidence of perjury and job and promotion buying, the Court denies the motion to quash the search warrant. Additionally, the Court finds that even if the affidavit were deficient, law enforcement’s good-faith reliance on the warrant was reasonable, and thus the Leon exception to the suppression rule also applies.” United States v. Patel, 2018 U.S. Dist. LEXIS 128225 (N.D. Ill. July 31, 2018).

Defendant filed a motion to reconsider a jurisdictional argument for a CSLI warrant in state court denied nearly a year ago. Carpenter doesn’t apply. United States v. Coles, 2018 U.S. Dist. LEXIS 129617 (M.D. Pa. Aug. 2, 2018).*