CA4: 31 day delay in getting SW for cell phone was unreasonable

The government’s 31 day delay in getting a search warrant for defendant’s cell phone after its seizure was unreasonable and required suppression of the alleged child pornography on the phone. Because defendant was sentenced to life, the error was not harmless. United States v. Pratt, 2019 U.S. App. LEXIS 3972 (4th Cir. Feb. 8, 2019).

The search of the defendant’s garage was found by the trial court to be by consent, and the evidence supports that conclusion. State v. Howell, 26 Neb. App. 842, 2019 Neb. App. LEXIS 37 (Feb. 8, 2019).*

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