A man remodeling defendant’s house found a USB port in the bathroom, and he gathered that the USB could be used to hook up a camera in the bathroom to record children visiting there. He took the device he found home and later looked at it. He talked to his girlfriend and decided to take it to the police. His own look at the device was a private search, and there was no agency with the police. Finally, the police did not need a warrant to obtain it from him because of exigency. United States v. Stephen, 2021 U.S. App. LEXIS 3 (8th Cir. Jan. 4, 2021).
Plaintiff’s Franks challenge fails because, removing the challenged statements from the search warrant affidavit, probable cause remained. Onwenu v. Bacigal, 2021 U.S. App. LEXIS 16 (6th Cir. Jan. 4, 2021).*