D.V.I.: GFE applies to searches before the court held U.S. to V.I. packages weren’t border searches

Applying its prior Baxter case, the District of the Virgin Islands holds that the border search exception doesn’t apply to mail and packages shipped from the Continental U.S. The searches here, however, predated Baxter, so the good faith exception applies. United States v. Tyson, 2019 U.S. Dist. LEXIS 212994 (D.V.I. Dec. 11, 2019).

The trial court’s failure to make findings of voluntariness of consent after Birchfield required remand. State v. Franklin, 2019 N.M. App. LEXIS 136 (Dec. 9, 2019).*

Defendant never raised his staleness challenge in the district court so it’s waived on appeal. To the extent that the court can determine it, it’s denied on the merits. This search warrant is not presumptively stale in a mere 12 hours. United States v. Evans, 2019 U.S. App. LEXIS 36635 (6th Cir. Dec. 11, 2019).*