In a trade secrets theft case, reliance on double hearsay in the affidavit for search warrant was not unreasonable. The source was the company defendant worked for. Defendant relies on the elements of the trade secrets theft law and argues that the affidavit failed to show probable cause. Without needing to decide whether the government had to show probable cause for each element, it did. Even so, the good faith exception clearly applies, too. United States v. Minh Hoang, 2019 U.S. Dist. LEXIS 191834 (D. Utah Nov. 4, 2019).
Officers responded to a domestic disturbance at defendant’s address. He’d opened the door for them to talk, but then shut the door, attempting to end the encounter. The officer put his foot in the door, and this was with exigency based on what the officer had on the dispatch call and what he’d learned there. United States v. Daniel, 2019 U.S. Dist. LEXIS 191923 (D. Mont. Nov. 5, 2019).*