The border search exception does not apply to searching defendant’s cell phone at Customs for proof of a domestic crime, here mail theft. United States v. Carpenter, 2023 U.S. Dist. LEXIS 11014 (N.D. Ill. Jan. 23, 2023).
The drug dog was already at the scene of the stop and the sniff done by another officer not conducting the stop did not add time to the stop. State v. Crane, 2023-Ohio-188, 2023 Ohio App. LEXIS 163 (5th Dist. Jan. 23, 2023).*
2255 petitioner’s Fourth Amendment ineffectiveness claim fails because he can’t show the underlying claim would prevail. United States v. Hensley, 2023 U.S. Dist. LEXIS 10996 (E.D. Ky. Jan. 23, 2023).*