D.Md.: No REP in jail calls even though warning was in English and def didn’t speak English

There is no reasonable expectation of privacy in jail calls to nonlawyers. The government didn’t show that defendants could even understand the warning in English on the phone, but it doesn’t matter. United States v. Reyes-Canales, 2019 U.S. Dist. LEXIS 111846 (D. Md. July 2, 2019).

The arrest warrant was issued on probable cause. Even if it wasn’t, there was good faith reliance on it which permits the search incident. The search warrant for his social media account and iPhone were issued on plenty of probable cause. His Franks challenge fails for lack of materiality. United States v. Parks, 2019 U.S. Dist. LEXIS 111121 (D. Md. July 3, 2019).*

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