Search of a rental car before Byrd that subsequently made it unreasonable gets the benefit of the good faith exception. United States v. Houston, 2021 U.S. App. LEXIS 1643 (4th Cir. Jan. 21, 2021).
There were material omissions from the affidavit for the search warrant. Turning to the probable cause question, the court doesn’t find that it undermined it. “However, the court has no difficulty concluding that the ‘corrected’ affidavit would establish probable cause to search the residence for controlled substances and firearms even upon consideration of the inserted facts. That is because the totality of the circumstances presented in the affidavit established a fair probability that contraband or evidence of a crime would be found in the residence.” United States v. Larnerd, 2021 U.S. Dist. LEXIS 10993 (M.D. Pa. Jan. 21, 2021).*