Misidentifying the homeowner in the affidavit for the warrant isn’t material because a search warrant runs against the place and the evidence inside. “The identity of the supposedly-misidentified person is irrelevant to the finding of probable cause to search the home, because the circumstances form a substantial basis to make that finding whether that person was Harper or anybody else.” United States v. Petrie, 2019 U.S. Dist. LEXIS 21541 (E.D. Mich. Feb. 11, 2019).
The search warrant for defendant’s cell phone was properly limited to child pornography images, and it did not permit a wholesale search of the phone. Commonwealth v. Green, 2019 PA Super 39, 2019 Pa. Super. LEXIS 126 (Feb. 12, 2019).*