Just because the government hasn’t yet accessed defendant’s iPhone because it can’t crack the code to unlock it doesn’t mean that defendant can get it back under Rule 41(g). It’s still potential evidence. United States v. Morgan, 2020 U.S. Dist. LEXIS 39884 (W.D. N.Y. Mar. 6, 2020).
A trash container search produced evidence of drugs likely associated with defendant’s home, and the search warrant was sufficiently particular. United States v. Hervey, 2020 U.S. App. LEXIS 7222 (10th Cir. Mar, 9, 2020).*
“[T]he Court finds that the confidential informant’s tip was sufficiently corroborated by law enforcement’s independent investigation. Thus, the Magistrate Judge had a ‘substantial basis’ within the four corners of the Wyrzykowski Affidavit for concluding that there was probable cause to find evidence of a marijuana grow operation at the Residence.” Besides, the good faith exception applies. United States v. Patterson, 2020 U.S. Dist. LEXIS 40378 (D.V.I. Mar. 9, 2020).*