AZ: Probation search could reasonably include cell phone because of nature of allegations

Defendant on felony probation and subject to a warrantless search condition. It was reasonable to search his cell phone under this condition because his mother reported threats and it was possible the cell phone’s contents could corroborate it. State v. Lietzau, 2019 Ariz. App. LEXIS 285 (Mar. 25, 2019).

Defendant was subjected to an arrest on an illegal warrant, but the search incident to the arrest of his briefcase at the time was valid. United States v. Abernathy, 2019 U.S. Dist. LEXIS 49448 (M.D. Tenn. Mar. 25, 2019).*

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