The search warrant for defendant’s cell phone was specific as to particular images but general as to others, and it is suppressed as to the others. “The fact that the media command limited the media search to ‘evidence related to the crimes under investigation’ did not cure the overbreadth.” State v. Serrano, 324 Or. App. 453, 2023 Ore. App. LEXIS 171 (Mar. 8, 2023).
Drug dog’s alert was admissible and reliable. The dog had been recertified and the alert was apparent on the video. United States v. Covington, 2023 U.S. App. LEXIS 5510 (3d Cir. Mar. 8, 2023).*
2254 petitioner litigated his Fourth Amendment claim in state court and on appeal, and he can’t raise it on habeas. Ray-El v. Schiebner, 2023 U.S. Dist. LEXIS 37822 (E.D. Mich. Mar. 6, 2023).*