D.P.R.: The fact the police statements weren’t the same doesn’t mean there’s a Franks violation or no PC

The officer’s statement wasn’t inconsistent with the reports of others and didn’t support a Franks claim. It’s entirely possible that the reports of others were all true and merely reported different observations than the officers. Therefore, no Franks violation. United States v. Esquilin-Martinez, 2018 U.S. Dist. LEXIS 135659 (D. P.R. Aug. 9, 2018).*

There was probable cause for the two places searched under the search warrants, and the good faith exception applied, too. United States v. Torner, 2018 U.S. Dist. LEXIS 134634 (M.D. Pa. Aug. 10, 2018).*

The defendant is incorrect that the information on defendant’s cell phone, allegedly illegally obtained before the search warrant was issued, made the search warrant issued on the original affidavit unreasonable. That information would have enhanced the probable cause, not lessened it, but there was probable cause without it. The R&R is adopted. United States v. Sullentrop, 2018 U.S. Dist. LEXIS 136136 (E.D. Mo. Aug. 13, 2018).*