D.S.D.: Failure to bring affidavit for SW to scene of search doesn’t obviate GFE

The affidavit for this search warrant was based on probable cause. “Law enforcement’s failure to bring the affidavit in support of the search warrant to the scene of the search is not fatal to the good-faith exception’s application. … The fact that the affidavit and application did not accompany the warrant did not factor into the Groh Court’s good-faith exception analysis. Rather, it played into the particularity analysis.” The officers were not negligent, and the search was objectively reasonable. United States v. Saddler, 2020 U.S. Dist. LEXIS 197165 (D. S.D. Oct. 23, 2020).

Calling in the drug dog within a minute didn’t have the drug dog extend the stop. State v. Pack, 2020-Ohio-5033, 2020 Ohio App. LEXIS 3875 (2d Dist. Oct. 23, 2020).*

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