The exclusionary rule applies to probation revocation proceedings in Pennsylvania. Having suppressed in the underlying criminal case, the court should have suppressed on the violation of probation. Commonwealth v. Parson, 2021 PA Super 151, 2021 Pa. Super. LEXIS 487 (July 28, 2021) (2½ years from conviction to reversal).
Defendant made a prima facie showing of a Franks violation to get a hearing. The warrant authorized a search for drug evidence, but not files that ended up showing child pornography. United States v. Hannah, 2021 U.S. Dist. LEXIS 139988 (C.D.Ill. July 27, 2021).*
There was probable cause to believe defendant committed the offense of wanton endangerment to justify a search warrant. The government didn’t have to show more about guilt. United States v. Brown, 2021 U.S. App. LEXIS 22358 (4th Cir. July 28, 2021).*