Defendant’s vehicle was factually connected to a shooting incident, and that gave probable cause to search it under the automobile exception. There was nexus to defendant’s cell phones found in the vehicle to get a separate search warrant for them. United States v. Woods, 2019 U.S. Dist. LEXIS 12820 (D. Minn. Jan. 28, 2019)*:
… These phones had a nexus to the Tahoe, Woods, or both and, by extension, are connected to the alleged shooting on May 18, 2018, the high-speed police chase that followed, and the contraband recovered from the Tahoe. In addition, a Confidential Reliable Informant (CRI) told police that Woods possesses a firearm (which Woods is ineligible to possess) and that Woods uses his cell phones to sell heroin. Also, in a recorded phone call that Woods made from jail on May 19, 2018, he used code words to discuss firearms and referred to individuals whose contact information he said was stored in his cell phone. Several days later, after police located an individual who Woods referred to in the recorded phone call, that individual told police that Woods had been involved in a recent murder.