Facebook’s merely copying defendant’s account for a search warrant was not a seizure. United States v. Perez, 2020 U.S. App. LEXIS 5541 (9th Cir. Feb. 21, 2020).
Probable cause existed for plaintiff’s arrest for constructive possession when she was found asleep and undressed in a drug house when a search warrant was executed. Suero v. City of New York, 2020 NY Slip Op 01301, 2020 N.Y. App. Div. LEXIS 1344 (1st Dept. Feb. 25, 2020).*