Defendant consented to the officer handling his secondary cell phone that wasn’t able to make calls. The officer accidentally saw child pornography on the phone in plain view, and it was all reasonable. Thomson v. State, 2022 Tex. App. LEXIS 6032 (Tex. App. – Houston (1st Dist.) Aug. 18, 2022).
There was probable cause for seizure of defendant’s motorcycle for forfeiture. On Rule 41(g), the court does not have to address whether it has evidentiary value. United States v. Engstrom, 2022 U.S. Dist. LEXIS 147071 (D. Nev. Aug. 17, 2022).
Uncorroborated statements about sex trafficking going on at defendant’s residence was still probable cause. United States v. Giles, 2022 U.S. Dist. LEXIS 147266 (E.D. Mich. Aug. 17, 2022).*
Having gotten defendant out of the car, there was a gun in plain view where he was reaching. State v. Kay, 2022-Ohio-2862, 2022 Ohio App. LEXIS 2696 (5th Dist. Aug. 17, 2022).*