E.D.Mich.: A year delay in searching this cell phone was not unreasonable when def was in custody

A year delay in searching defendant’s cell phone was not unreasonable. He was a parolee, in custody, and had a significantly reduced privacy interest in the phone. United States v. Davis, 2021 U.S. Dist. LEXIS 175204 (E.D.Mich. Sept. 15, 2021).

The government’s motion to extend the time to search a multitude of cell phones seized in an investigation is granted. “When operating under  Rule 41(e)(2)(B), ‘the Fourth Amendment requires the government to complete its review . . . within a ‘reasonable’ period of time.'” United States v. Gonzalez-Rivera, 2021 U.S. Dist. LEXIS 175719 (W.D.N.Y. Sept. 14, 2021).

There is no Fourth Amendment right for an inmate to be housed in a particular prison. Brigham v. Corcoran, 2021 U.S. Dist. LEXIS 167058 (D.Conn. Sept. 1, 2021).*

Defendant didn’t include the search warrant materials in the record on appeal, so the issue is waived. English v. State, 2021 Tex. App. LEXIS 7653 (Tex. App. – Houston (1st Dist.) Sept. 16, 2021).*