The delay between seizing defendant’s cell phones and searching them wasn’t unreasonable considering he was in jail and would have had no access to them anyway. United States v. Carey, 2020 U.S. Dist. LEXIS 1150 (M.D. Pa. Jan. 6, 2020).
There was probable cause for a pharmacy’s records based on over-prescribing Oxys in multiple prescriptions to the same persons. United States v. Nasr, 2020 U.S. Dist. LEXIS 1460 (E.D. Ky. Jan. 6, 2020).*