A 14 month delay between seizure and search of defendant’s cell phone was not unreasonable because the phone would not have been returned to defendant in any event. Plus, he was in jail and couldn’t possess it. United States v. Taylor, 2019 U.S. Dist. LEXIS 25262 (W.D. Wash. Feb. 16, 2019).
The CI was named and gave information against penal interest, and it was detailed and corroborated and it gave probable cause. The state’s good faith exception argument is moot. State v. Foster, 2019 N.C. App. LEXIS 155 (Feb. 19, 2019).
Part of the motion to suppress isn’t timely, and it is therefore waived. United States v. Johnson, 2019 U.S. Dist. LEXIS 26097 (S.D. N.Y. Feb. 19, 2019).*