Defendant’s motion for a Franks hearing on his arrest warrant was mooted by his indictment. Young v. State, 2019 Ga. LEXIS 55 (Feb. 4, 2019).
Defendant was a sheriff’s deputy, and he was suspected of sexual misconduct with a minor. His wife consented to entry into the home and seizure of his cell phone. A search warrant was used to access it. There was probable cause as to the phone: “The juvenile female interviewed by Sergeant Bailey disclosed that she communicated with Mr. Wilson on Facebook and SnapChat, which are social media applications frequently accessed on a cell phone. Additionally, the juvenile female reported receiving a ‘selfie’ of Mr. Wilson that he likely took on a cell phone.” United States v. Wilson, 2019 U.S. Dist. LEXIS 16443 (W.D. Mo. Jan. 17, 2019).*