CA11: A cell phone with 2kg of heroin and cash is PC for the phone

“[L]aw enforcement officers had probable cause to obtain a warrant to search the cell phone because it was found in a truck with two kilograms of heroin and $24,000 of loose currency during the investigation into the heroin-distribution conspiracy.” CoA denied. Lark v. United States, 2020 U.S. App. LEXIS 24273 (11th Cir. July 31, 2020).*

Defense counsel was not shown ineffective for not arguing the traffic stop was unreasonably prolonged when defendant doesn’t show any underlying facts at all. United States v. Irvin, 2020 U.S. Dist. LEXIS 136316 (W.D. Va. July 31, 2020).*

In dismissing a pro se Fourth Amendment § 1983 case, the court takes judicial notice of the public docket of all the underlying state court cases against plaintiff. Grundy v. Akron Police Dep’t, 2020 U.S. Dist. LEXIS 136332 (N.D. Ohio July 31, 2020).*

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