N.D.Ohio: Officers knew def had CP on cell phone; finding cell phone in plain view permitted seizure

Even assuming the search warrant covered only under the roof, defendant’s cell phone was found in plain view on the driveway and it’s incriminating nature was already known to the officers, therefore, readily apparent. United States v. O’Neill, 2019 U.S. Dist. LEXIS 133852 (N.D. Ohio Aug. 9, 2019).*

The trial court found consent to search voluntary on the totality, and its holding is supported by the evidence (which is detailed for us). State v. Burton, 2019 Conn. App. LEXIS 307 (Aug. 13, 2019).*

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