IA: Shots fired call where officers heard of a man slumped over a railing and saw cars struck by bullets was exigent circumstances for entry

The community caretaking function justified the warrantless entry here into defendant’s apartment. Officers responded to a shots fired call at an apartment complex, saw bullet damage to cars, and had a report of a person slumped over a balcony railing. State v. Youm, 2022 Iowa App. LEXIS 676 (Aug. 31, 2022).

There were sufficient exigent circumstances for seizure of defendant’s cell phone when he was questioned for a murder. The search warrant for it was issued two days later [, and he doesn’t complain about the delay, but he really couldn’t anyway]. Defendant also consented to the officer scrolling through the phone during the police interview. Rafiq v. State, 2022 Tex. App. LEXIS 6575 (Tex. App. – Beaumont Aug. 31, 2022).*

Accessing defendant’s call logs and subscriber information was not a search. The warrant for 74 days of CSLI in this homicide case was based on probable cause and was with good faith. Martinez v. State, 2022 Tex. App. LEXIS 6562 (Tex. App. – San Antonio Aug. 31, 2022).*

In this NCO stalking case, flying a drone over the complainant’s house as a part of the stalking violated her reasonable expectation of privacy. Rosaly v. Konecny, 2022 Fla. App. LEXIS 5901 (Fla. 4th DCA Aug. 31, 2022).