E.D.Mo.: CLSI warrant obtained 3½ years before Carpenter was clearly with PC

The CLSI search warrant was obtained 3½ years before Carpenter, and assuming for the sake of argument that a warrant was required. It clearly showed probable cause to get the information. United States v. Johnson, 2019 U.S. Dist. LEXIS 65896 (E.D. Mo. Mar. 11, 2019), adopted, 2019 U.S. Dist. LEXIS 64774 (E.D. Mo. Apr. 16, 2019).*

“[T]he Court recommends the District Court find that the stop, though pretextual, was a valid Terry stop, and the continuation of the stop was supported by probable cause upon two officers’ detection of the plain smell of marijuana.” The frisk of defendant’s person was reasonable in its inception and scope. United States v. Sleet, 2019 U.S. Dist. LEXIS 64854 (E.D. Ky. Mar. 25, 2019).*