A probation search of a cell phone is permitted under a provision in the search condition for searching “personal effects.” United States v. Ard, 2018 U.S. Dist. LEXIS 187125 (E.D. La. Nov. 1, 2018).
There’s no evidence that NCMEC’s search expanded the private search, and there was probable cause. United States v. Wilbert, 2018 U.S. Dist. LEXIS 187024 (W.D. N.Y. Nov. 1, 2018).*