D.Ariz.: No constitutional obligation for officers to keep investigating past having PC

“To the extent that Plaintiffs’ claim is based on Defendant Pelham’s failure to conduct a more thorough investigation before seeking a warrant, it likewise fails. Plaintiffs allege that Defendants ‘failed to undertake minimally adequate investigative steps before seeking a warrant[.]’ … However, ‘[o]nce he has probable cause, an officer is not ordinarily required to continue to investigate or seek further corroboration.’ Ewing v. City of Stockton, 588 F.3d 1218, 1227 (9th Cir. 2009); U.S. v. Thoms, 2011 WL 87337, at *3 (D. Alaska 2011). …” Baker v. Pelham, 2026 U.S. Dist. LEXIS 106636 (D. Ariz. May 14, 2026).

“Given the facts that the police officers smelled marijuana on Walker’s person, he had just exited his vehicle, and he admitted that there was weed and a gun in the car, the officers lawfully searched and impounded Walker’s vehicle for their safety and to safeguard any evidence that could be concealed or destroyed. We determine from this record that the trial court did not err when it denied Walker’s motion to suppress.” State v. Walker, 2026-Ohio-1767 (8th Dist. May 14, 2026).*

There is no reasonable expectation of privacy in non-legal jail calls. United States v. Mendoza, 2026 U.S. Dist. LEXIS 106384 (M.D. Pa. May 14, 2026).*

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