When multiple cell phones and drugs are found together in a car, it’s a reasonable conclusion the cell phones are related to drug trafficking. The search of the phones reasonably led to child porn. United States v. Morton, 2022 U.S. App. LEXIS 23735 (5th Cir. Aug. 22, 2022).
Just because the officer only had information that defendant was involved in misdemeanor possession doesn’t mean the investigation should cease under Virginia v. Moore. United States v. Logan, 2022 U.S. Dist. LEXIS 153497 (N.D. Ohio Aug. 25, 2022).*
“In sum, while the warrants contemplated a broad set of searches, the nature of the scheme for which probable cause was established—a conspiracy lasting more than one year involving numerous suspects and comprising multiple violent acts and possible motives—and the totality of the circumstances supporting probable cause made a broad search constitutionally permissible.” United States v. Zottola, 2022 U.S. Dist. LEXIS 153418 (E.D.N.Y. Aug. 25, 2022).*