There was exigency for an emergency cell phone ping to locate defendant. He’d just committed enough crimes to get sentenced to life and he was on the run from police. State v. Snell, 2019 Del. Super. LEXIS 249 (May 21, 2019).
There were no intentional misstatements in the telephonic search warrant application. Words and phrases could be argued over, but the tenor as a whole showed probable cause with or without them. United States v. Phillips, 2019 U.S. Dist. LEXIS 87072 (D. Nev. May 23, 2019).*