“Additionally, when a warrantless search of a vehicle could have been conducted on the scene pursuant to the automobile exception, a warrantless search is also justified after the vehicle has been impounded and immobilized as long as probable cause still exists. Florida v. Meyers, 466 U.S. 380, 382 (1984) (per curiam) (citing Michigan v. Thomas, 458 U.S. 259 (1982) (per curiam); Chambers v. Maroney, 399 U.S. 42 (1970)).” Here, the car had to be jump started, and the second search was 13 days later. United States v. Caldwell, 2021 U.S. App. LEXIS 23202 (4th Cir. Aug. 3, 2021).
The seizure of defendant’s vehicle for a later search was with probable cause. A search warrant was issued for it, and his Franks challenge fails. United States v. Suggs, 2021 U.S. Dist. LEXIS 146598 (W.D.Pa. Aug. 5, 2021).*
There was probable cause for the warrant despite it being based in part on a CI. Defendant doesn’t get a Franks hearing. United States v. Nero, 2021 U.S. Dist. LEXIS 146759 (E.D.Mich. Aug. 5, 2021).*
There was probable cause for issuance of the search warrant. The CI’s information was followed up by corroboration. Brown v. United States, 2021 U.S. Dist. LEXIS 146897 (C.D.Ill. Aug. 5, 2021).*