E.D.Mich.: Possible 5A violation in obtaining cell phone passcode mooted by inevitable discovery; they’d get into it anyway

The government obtained defendant’s cell phone passcode by questioning him. Despite the potential Fifth Amendment violation, the court finds that the cell phone would have been opened by the government’s forensics team anyway, so inevitable discovery applies. United States v. Ahmad, 2026 U.S. Dist. LEXIS 88794 (E.D. Mich. Apr. 22, 2026).

Defendant’s stop may have been pretextual, but there was an objective basis for it. State v. Winslow, 2026 Tenn. Crim. App. LEXIS 228 (Apr. 23, 2026).*

“After independent review, the Court is satisfied that Judge Markovich’s recommendation is sound. Agent Ramirez provided several distinct factors that contributed to his decision to stop Defendant’s vehicle: Defendant was driving near the border on a route known for smuggling, he was behaving nervously and seemed to be hyper-focused on Agent Ramirez’s vehicle, and the vehicle had characteristics of vehicles that, in Agent Ramirez’s training and experience, are often used for smuggling (e.g., it was an older vehicle with temporary plates and looked to be weighed down). Under the totality of the circumstances, these factors gave rise to reasonable suspicion.” United States v. Minfee, 2026 U.S. Dist. LEXIS 85822 (D. Ariz. Apr. 20, 2026),* adopting 2026 U.S. Dist. LEXIS 57635 (D. Ariz. Mar. 19, 2026).*