S.D.Fla.: Inventory that omitted “miscellaneous personal items” was not unreasonable

A “clumsy” inventory that omitted “miscellaneous personal items” was not an unreasonable inventory. No level of specificity is required. United States v. Samuels, 2026 U.S. Dist. LEXIS 96304 (S.D. Fla. May 1, 2026).

The CSAM search warrant here for ten years’ worth of information in specific categories was not overbroad. The state alleged information that supported ten years’ worth. Defendant argues that they were only entitled to two months’ worth. State v. Difilippo, 2026 Del. Super. LEXIS 201 (Apr. 24, 2026).*

Defendant got six extensions of time to file a suppression motion and was still untimely. Exercising discretion, the court goes to the merits [likely to preempt an IAC claim] and finds the search warrant was issued with probable cause based on reliable informant hearsay. United States v. Hardison, 2026 U.S. Dist. LEXIS 95414 (E.D. Tenn. Apr. 30, 2026).*

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