Defendant got a suppression hearing, but not yet a Franks hearing. The USMJ was “on the fence” about whether a Franks hearing was required. Ultimately the findings of fact and conclusions of law supported a lack of materiality on the alleged false claims, even without it being called a Franks hearing, and this was not error. United States v. Miller, 2019 U.S. Dist. LEXIS 221515 (N.D. Iowa Dec. 27, 2019).
Police had probable cause to seize defendant’s cell phone for possible child pornography on it to enable them to get a search warrant for it. United States v. Wainright, 2019 U.S. Dist. LEXIS 221489 (W.D. Mo. Dec. 27, 2019).*