The order suppressing a laptop search is reversed. The computer was seized under a state search warrant but searched under a federal warrant. Even if probable cause was lacking for the issuance of the search warrant, it was close enough and the good faith exception applies. Also, the 21 day delay between seizure and search was not unreasonable. Nothing in the record suggests a systemic failure, and the officer’s conduct was not sufficiently culpable to warrant suppression. United States v. Jobe, 2019 U.S. App. LEXIS 23798 (9th Cir. Aug. 9, 2019).
In this 2255, there is no indication that the search warrant requirements for CSLI were violated or that Carpenter would be retroactive. Denied. United States v. Carranza, 2019 U.S. Dist. LEXIS 134024 (S.D. Tex. Aug. 9, 2019).*