The affidavit for search warrant was based on probable cause. Review in a motion to suppress is not de novo. United States v. Harper, 2021 U.S. Dist. LEXIS 162543 (D.N.J. Aug. 26, 2021).
Defendant was stopped with reasonable suspicion, and he consented to the officer looking at text messages with one person (whom the officers believed was a co-conspirator) and one confirmed drug sales. “As discussed above, having found that Defendant’s initial detention was constitutional, the Court need not address the second step. As such, the Court finds that Defendant’s limited consent to search his text messages with Johnson was valid.” United States v. Rideaux, 2021 U.S. Dist. LEXIS 162953 (W.D.La. July 28, 2021).*