Defendant was on state parole living with his girlfriend, also a defendant. They were out and her mother was their babysitter in the home. Parole came by for a compliance check. The mother let them in. First, the search was valid under the totality of the circumstances under Samson. Second is consent; mom was not just any babysitter. She was there several times a week. United States v. Abraham, 2022 U.S. Dist. LEXIS 216691 (E.D. Mich. Dec. 1, 2022).
There is no reasonable expectation of privacy in a contraband cell phone in prison or the calls it makes. United States v. Yandell, 2022 U.S. Dist. LEXIS 216703 (E.D. Cal. Nov. 30, 2022).*
It was reasonable to order the driver and passenger out of the car in a stop, and that led to a valid plain view. Suppression reversed. State v. Kildow, 2022 Ida. App. LEXIS 20 (Dec. 1, 2022).*
To the officers, the facts presented added up to a burglary in progress, and that justified a warrantless entry. United States v. Chavez, 2022 U.S. Dist. LEXIS 216541 (D.N.M. Dec. 1, 2022).*