The search warrant was properly issued on affidavit. It didn’t have to be signed in the presence of the judge. An oral affidavit has to be, but this isn’t. State v. Hensley, 2018 Ida. App. LEXIS 49 (Nov. 16, 2018).
Park Police stop: “As discussed above, Sergeant Koehler’s other statements in his telephonic application sufficiently establish probable cause for the issuance of the search warrant, so suppression of the evidence of the blood draw in this case is not warranted. For these reasons, Defendant’s Motion to Suppress and for a Franks Hearing (ECF No. 30) is DENIED.” United States v. Zabalaga, 2018 U.S. Dist. LEXIS 194965 (D. Md. Nov. 15, 2018).*
CSLI lawfully obtained two years before Carpenter would not be excluded. United States v. Gyamfi, 2018 U.S. Dist. LEXIS 194235 (S.D. N.Y. Nov. 15, 2018).*