Defendant was subjected to a probation search of a cell phone where the underlying crime had nothing to do with cell phones or the internet. The dissent believes that Riley and Sansom together require reasonable suspicion for a cell phone probation search despite state law permitting suspicionless searches in general. People v. Salcido, 2019 Cal. App. LEXIS 407 (4th Dist. May 2, 2019).
“We have reviewed the warrant affidavit and agree with the district court that, even if the warrant was not supported by probable cause, the affidavit contained sufficient indicia of probable cause such that the officer’s reliance on the warrant was objectively reasonable.” United States v. Goldsberry, 2019 U.S. App. LEXIS 13166 (4th Cir. May 1, 2019).*