Defendant was arrested in what was alleged to be an unlawful entry. After he was out, he requested his cell phone so he could call a lawyer. Going back in with him and the protective sweep with it was by consent and was reasonable. United States v. Barr, 2018 U.S. Dist. LEXIS 188067 (N.D. Ga. Oct. 17, 2018), adopted, 2018 U.S. Dist. LEXIS 187827 (N.D. Ga. Nov. 2, 2018).
The exclusionary in revocation proceedings only applies for egregious violations of the Fourth Amendment. This isn’t. Also, accessing third-party data isn’t protected by the Fourth Amendment. United States v. Wright, 2018 U.S. App. LEXIS 31138 (9th Cir. Nov. 2, 2018).*