LA: False statement in affidavit passed from another officer was harmless on PC question

The statement the officer used in the affidavit came from another officer. At worst it was negligent and not an intentional misrepresentation. No matter what, however, it doesn’t undermine the probable cause, so the motion was properly denied. State v. Turner, 2018 La. LEXIS 3341 (Dec. 5, 2018).*

The search of defendant’s cell phone was harmless because nothing from it was used at trial. It was with a warrant. State v. Jenkins, 2018-Ohio-4814, 2018 Ohio App. LEXIS 5138 (9th Dist. Dec. 5, 2018).*