W.D.N.Y.: Failure to preserve a recording of issuance of a SW required by NY law is not a 4A issue

Failure to preserve a recording of issuance of a search warrant as required by New York law is not a Fourth Amendment issue. United States v. Bailey, 2021 U.S. Dist. LEXIS 212869 (W.D.N.Y. Nov. 3, 2021).

“Recognizing that this case is pending in the Eleventh Circuit rather than the Ninth, Grimes concedes that binding precedent permits CBP officers like the ones in this case to conduct a search of a traveler’s electronic devices without reasonable suspicion when a person is entering the United States, and Grimes acknowledges that his motion will be denied.” United States v. Grimes, 2021 U.S. Dist. LEXIS 212230 (N.D.Ga. Sept. 28, 2021).

In extraditions, “The standard of proof to find evidence ‘sufficient to sustain the charge’ pursuant to 18 U.S.C. § 3184 is equivalent to the domestic requirement of probable cause.” In re Extradition of Villegas, 2021 U.S. Dist. LEXIS 212646 (W.D.Tex. Oct. 29, 2021).