There were exigent circumstances for seizure of defendant’s cell phone incident to his arrest and probable cause for a search warrant to search it. The police developed information that the conspirators communicated with the victim by phone before the crime. His Franks challenge fails for a lack of an offer of proof. State v. Sayles, 2021 Conn. App. LEXIS 43 (Feb. 23, 2021).
Defendant is a dentist who failed to adequately respond to a subpoena duces tecum for records. Then the State applied for a court order to enter the practice to search for the records. Defendant’s failure to challenge the constitutionality of the trial court to issue the order for noncompliance with the subpoena waives it for appeal. Comm’r of Pub. Health v. Colandrea, 2021 Conn. App. LEXIS 47 (Feb. 23, 2021) [seems overly technical to me].