In determining probable cause, “reliable hearsay” may be considered. State v. Dixon, 2022 Minn. LEXIS 483 (Nov. 9, 2022).
The question of lack of probable cause was not in the motion to suppress, but the trial court held there was, so the issue is presented for appellate review. People v. Rivera, 2022 NY Slip Op 06268, 2022 N.Y. App. Div. LEXIS 6105 (2d Dept. Nov. 9, 2022).*
Defendant has Asperger’s and lives in an adult foster home. The responsible people there confiscated his electronics because he had child pornography on them, and they turned them over to the police. This was purely a private search under the Fourth Amendment and the state constitution. When they were seized, there was no police investigation going on at all. State v. Larson, 2022 MT 223, 2022 Mont. LEXIS 1038 (Nov. 9, 2022).*