The search warrant for defendant’s cell phones had inserted “no charge at this time” for the crime under investigation. The phone was seized without a warrant from a traffic stop, then searched under the warrant, but you can’t tell what the government was looking for because nothing was attached to limit the search. Finally, the warrant is so deficient that the good faith exception doesn’t apply. United States v. Etienne, 2019 U.S. Dist. LEXIS 77256 (N.D. Cal. May 8, 2019).
The search warrant was particular under the affidavit for the warrant. People v. Crupi, 2019 N.Y. App. Div. LEXIS 3612 (2d Dept. May 8, 2019).*