D.P.R.: Cut-and-paste error that misidentified iPhone model overlooked by correct phone number

The search warrant was for a specific phone number on an iPhone 6S, but the phone with that number was an iPhone 13. Still, the phone number controlled, and the search was valid. Alternatively, on the totality, defendant consented to the search. United States v. González-Arocho, 2024 U.S. Dist. LEXIS 18250 (D.P.R. Jan. 25, 2024).

“Defendant’s motion presents a straightforward legal question, albeit in a burgeoning and undefined area of Fourth Amendment jurisprudence: does a law enforcement officer’s warrantless inspection of a digital file provided to the officer and identified as a hash value match to child pornography by a private internet service provider (in this case, Google) constitute an unreasonable search in violation of the Fourth Amendment? The court finds that it does not. Accordingly, and for the reasons that follow, the motion to suppress is DENIED.” United States v. Lowers, 2024 U.S. Dist. LEXIS 19233 (E.D.N.C. Feb. 5, 2024).*

Defendant’s jerky driving in his own lane justified his stop because it suggested DUI. United States v. Costa, 2024 U.S. Dist. LEXIS 19242 (D.S.D. Feb. 1, 2024).*