CA9: Police following a blood trail onto curtilage after recent crime was exigency

The district court concluded defendant had no standing to challenge a tribal police search of the curtilage of his grandmother’s house where he was an overnight guest. Assuming, without deciding, he has standing, there was clear and obvious exigency for at least the second search after police followed a blood trail plus his grandmother’s consent. United States v. Ish, 2020 U.S. App. LEXIS 23119 (9th Cir. July 23, 2020).

The digital search warrant for Facebook records was ostensibly overbroad, but it was the issuing magistrate’s error, not the officer’s. The warrant was executed reasonably, and suppression here would serve no deterrent purpose. United States v. Purcell, 2020 U.S. App. LEXIS 23061 (2d Cir. July 23, 2020).

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