OH6: Def’s neighbor was citizen informant in reporting seeing him looking at CP through an open window

Defendant’s neighbor could see him from his house masturbating to child pornography. He called the police and the police corroborated it but walked on the curtilage, too. The neighbor was shown as a confidential informant but was really a citizen informant. There was probable cause shown in the affidavit for the warrant, and the good faith exception applied as well. State v. Long, 2020-Ohio-4090 (6th Dist. Aug. 14, 2020).*

The government corroborated what it could of their first time informant, and this provided probable cause for the search warrant. The affidavit also showed sufficient nexus to two premises associated with defendant. United States v. Miles, 2020 U.S. Dist. LEXIS 146653 (E.D. Mich. Aug. 14, 2020).*

The government showed probable cause for issuance of a tracking warrant on defendant’s cell phone (pre-Carpenter). United States v. Fisher, 2020 U.S. Dist. LEXIS 146897 (D. Minn. Aug. 14, 2020).*

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