CA4: Info known by officer but not included in affidavit can be considered in applying GFE

Defendant’s phone was lawfully seized incident to his arrest and then geting a search warrant. “We agree with the district court that the evidence obtained from Thomas’s phone is admissible under Leon. Our precedents make clear that in assessing an officer’s objective good faith in executing a search warrant, we may consider facts known to the officer, but inadvertently omitted from a warrant affidavit. And under all the circumstances presented here, Coleman had a reasonable basis to believe there existed probable cause to search Thomas’s phone. Accordingly, we affirm the judgment of the district court.” United States v. Thomas, 2018 U.S. App. LEXIS 31691 (4th Cir. Nov. 8, 2018).*

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