Defendant made no attempt to show standing in the cell phone of another person that was lawfully seized incident to his arrest and in his pocket. He needed his own testimony or that of another to establish it. United States v. Hamlett, 2018 U.S. Dist. LEXIS 166762 (D. Conn. Sep. 28, 2018).
Defendant’s SnapChat video showing firearms led to a valid probation search. There was also voluntary consent. State v. Love, 2018 Del. Super. LEXIS 412 (Sep. 27, 2018).*