CSLI warrant was particular when it described the phone number and time period and didn’t have to name the phone owner. Commonwealth v. Davis, 2020 Pa. Super. LEXIS 885 (Oct. 23, 2020).
The officer spent a week corroborating the CI, and that corroboration showed probable cause. Cell phones found in an “anonymous bedroom” not tied to any person nor in the pocket of any clothes could be seized and then searched under the warrant. United States v. Stewart, 2020 U.S. Dist. LEXIS 197106 (E.D. Wis. Oct. 23, 2020).
Defendant’s challenge to the affidavit for search warrant is denied. His Franks challenge fails as negligence at worst and not material to the finding of probable cause. United States v. Frazier, 2020 U.S. Dist. LEXIS 197031 (D. Conn. Oct. 23, 2020).*