D.Ariz.: SW for text messages prior to date of offense suppressed, after date were proper

The issuing magistrate properly issued a search warrant for text messages on defendant’s cell phone for a particular date and thereafter by inference. Prior to that particular date is suppressed for lack of probable cause. United States v. Bowen, 2019 U.S. Dist. LEXIS 99200 (D. Ariz. June 12, 2019), adopting 2019 U.S. Dist. LEXIS 100150 (D. Ariz. April 16, 2019).

There is a statutory exclusionary rule on license suspensions if the officer makes a stop without jurisdiction. The court declines to extend it to any other situation where there is a problem with the stop. Westra v. Iowa DOT, 2019 Iowa Sup. LEXIS 77 (June 15, 2019).*

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