Defendant’s alleged theft of a firearm the day before was not an exigent circumstance for a warrantless entry into his home. Commonwealth v. Gray, 2019 PA Super 175, 2019 Pa. Super. LEXIS 541 (May 31, 2019). In fact, the person who lost the firearm found it in her home shortly thereafter.
Rule 41 doesn’t apply to a state issued search warrant for CSLI information despite the fact it was obvious defendant was driving 15 hours to California and coming right back. A Montana state court could still have handled the case. The search warrant for CSLI was issued with probable cause and the judge had jurisdiction. United States v. Ortega-Yescas, 2019 U.S. Dist. LEXIS 90778 (D. Mont. May 31, 2019).*