CA6: Seizure of cell phone under SW had to be within time prescribed but the actual off-site search can be later

The seizure of the cell phone was within the time prescribed in the search warrant, but the actual search of the phone didn’t occur until after the time prescribed. This did not violate the Fourth Amendment. Off-site analysis was expected and is what usually happens. United States v. Cleveland, 2018 U.S. App. LEXIS 29505 (6th Cir. Oct. 19, 2018).

Defendant’s CSLI was obtained pre-Carpenter under existing law, and the good faith exception would be applied. United States v. Wright, 2018 U.S. Dist. LEXIS 179013 (D. Nev. Oct. 18, 2018).

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