The search of defendant’s car ostensibly under the automobile exception fails under Collins v. Virginia. It was clearly on the curtilage, and the exclusionary rule is applied. United States v. Bautista, 2018 U.S. Dist. LEXIS 197792 (D. Ariz. Nov. 20, 2018).
The CI was corroborated by trash pulls and more investigation, and the USMJ had a substantial basis for finding probable cause. United States v. Rohe, 2018 U.S. App. LEXIS 32425 (11th Cir. Nov. 16, 2018).*
Defense counsel wasn’t ineffective for not challenging the border search of his cell phone because it was valid no matter how you look at it. United States v. Cobb, 2018 U.S. Dist. LEXIS 196190 (D. R.I. Nov. 17, 2018).*