Inevitable discovery applies: “The District Court based its decision to admit evidence from Restitullo’s apartment on three factors. First, police drafted the warrant application before Restitullo’s interrogation began. Second, ‘overwhelming’ probable cause existed to search Restitullo’s bedroom based on the interviews of his two purported victims—interviews that occurred even before officers took Restitullo into custody. And third, the police secured Restitullo’s apartment before Restitullo’s interrogation. Securing the apartment thus prevented any possible removal of the evidence.” United States v. Restitullo, 2019 U.S. App. LEXIS 35585 (3d Cir. Nov. 27, 2019).
Playpen search warrant sustained. United States v. Smith, 2019 U.S. App. LEXIS 35611 (5th Cir. Nov. 26, 2019).*