Defendant had a cell phone seized from him in 2009 that remained in the police evidence room. After another crime, this time a capital murder, the phone was searched with a warrant in 2018. The delay wasn’t unreasonable because defendant never asserted recovery of the phone. Harmel v. State, 2020 Tex. App. LEXIS 1584 (Tex. App. – Austin Feb. 26, 2020).
Eight day delay from NYSP taking possession of defendant’s devices for suspected child pornography and then seeking a search warrant wasn’t an unreasonable delay. United States v. Schohn, 2020 U.S. Dist. LEXIS 32195 (W.D. N.Y. Jan. 2, 2020),* adopted, 2020 U.S. Dist. LEXIS 31222 (W.D.N.Y. Feb. 24, 2020).*