Defendant had texted a copy of a photograph of his AK-47 on his cell phone to another, and the police saw it. That gave cause and an independent source to search the phone for it. “We agree with the district court that law enforcement would have sought a warrant regardless of the illegal search” of the phone. United States v. Bell, 2019 U.S. App. LEXIS 16534 (7th Cir. June 3, 2019).
A change in the law about searches of luggage coming in flights from the U.S. to the Virgin Islands was subject to the good faith exception for those searches occurring before. The border search of cell phones was reasonable and with good faith. United States v. Thomas-Okeke, 2019 U.S. Dist. LEXIS 92345 (D. V.I. June 3, 2019).*