The court sustains a nighttime search warrant based solely on the fact that there were some sales of drugs from the house without specifying the time, and that it was “urgent” that the raid happen now for drugs, potential weapons, and money. State v. Noble, 2020-Ohio-695, 2020 Ohio App. LEXIS 634 (2d Dist. Feb. 27, 2020). [I’m not buying. Nighttime searches are inherently dangerous and should be avoided except where really necessary, and the state didn’t show that here. Treatise § 58.22.]
To the court’s knowledge, no case has held that a parole search of a cell phone is unreasonable. Parolees have only an extremely limited expectation of privacy. Suspicion of a residential burglary is reason enough to search the phone. People v. Delrio, 2020 Cal. App. LEXIS 171 (1st Dist. Feb. 28, 2020).