PA: SW for cell phone extraction executed after expiration was treated as a warrantless search

A search warrant executed on cell phones for extraction of data expired four days before the search. Therefore, the search was warrantless, and the trial court should have suppressed. Commonwealth v. Bowens, 2020 Pa. Super. LEXIS 22 (Jan. 17, 2020).

Defendant’s claim that his cell phones were unlawfully searched without a search warrant is speculative at best. The government showed probable cause from the conversations about what was to be paid in support of the money laundering allegation. United States v. Marley, 2020 U.S. App. LEXIS 1530 (2d Cir. Jan. 15, 2020).*

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