“The defendant’s boilerplate claim that the ‘information used to obtain the search warrant from the Circuit Court judge was flawed with false allegation….’, … does not meet the Franks test for a hearing.” “While defendant did not explicitly argue that there was no probable cause to support the authorization to search for cell phones or electronic devices, the Court will consider this issue given defendant’s general arguments concerning the lack of probable cause.” There clearly is. United States v. Brown, 2018 U.S. Dist. LEXIS 202866 (W.D. Mo. Nov. 30, 2018).
Defendant’s arrest in a public place on probable cause required no arrest warrant. United States v. Segura-Gomez, 2018 U.S. Dist. LEXIS 203189 (E.D. N.C. Nov. 30, 2018).*