IN: Warrant-placed GPS unit’s failure is not PC to believe defendant stole it

Just because a GPS device lawfully planted on a car stops working is not probable cause to believe the defendant stole it. The search warrant for his house and barn to recover it lacked all probable cause and any basis for the good faith exception to apply. Heuring v. State, 2020 Ind. LEXIS 98 (Feb. 20, 2020).

Defendant was searched as a result of a stalking arrest, and the subsequent invalidation of the stalking statute in state court didn’t invalidate the search under Krull and DeFillipo. Fredin v. Clysdale, 2020 U.S. App. LEXIS 5157 (8th Cir. Feb. 20, 2020).*

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