The government obtained a roving wiretap for defendant’s cell phone with a cell site simulator. In the warrant application, they described in detail what a cell site simulator was, but it never said the words “cell site simulator.” It doesn’t undermine the probable cause. United States v. Tutis, 2021 U.S. App. LEXIS 3899 (3d Cir. Feb. 11, 2021).
Defendant was stopped for a traffic offense and crack cocaine crumbs were seen on his shirt. That justified a vehicle search under the automobile exception. People v. Bethea, 2021 NY Slip Op 00976, 2021 N.Y. App. Div. LEXIS 965 (4th Dept. Feb. 11, 2021).*
A state’s attorney authorizing issuance of an arrest warrant for plaintiff was reasonable and entitled the defendant officer to qualified immunity. Shrewsbury v. Williams, 2021 U.S. App. LEXIS 3955 (4th Cir. Feb. 11, 2021).*