A probation search of defendant’s cell phone was based on reasonable suspicion that defendant violated his conditions of supervised release. The later warrantless forensic review of his phone was unreasonable. United States v. Brownlee, 2020 U.S. Dist. LEXIS 103839 (M.D. Pa. June 15, 2020).
It was reasonable for officers to believe the occupant had authority to consent to a search of what turned out to be defendant’s suitcase. There were no identifying marks on it. Thus, it was reasonable to consider the contents of the suitcase in applying for a search warrant for the house. Bryant v. Commonwealth, 2020 Va. App. LEXIS 176 (June 16, 2020).*