D.R.I.: Binding circuit precedent not required for Davis to save pre-Jones GPS

Binding circuit precedent not really required for pre-Jones GPS monitoring to be valid under the good faith exception. A substantial consensus of lower courts is enough for good faith to apply. United States v. Oladosu, 887 F. Supp. 2d 437 (D. R.I. 2012).

The affiant officer’s “statement of the frequent existence of electronic records kept on drug dealers’ cell phones” coupled with other probable cause to arrest was probable cause to search defendant’s telephone. United States v. Sias, 2012 U.S. Dist. LEXIS 116841 (D. Neb. August 20, 2012).*

Probable cause was shown for the search of defendant’s computer, even though the warrant was issued nine days after seizure. Defendant was in custody in the interim, too, and he didn’t argue detention of the computer was unreasonable under United States v. Place. United States v. Farmer, 2012 U.S. Dist. LEXIS 117843 (N.D. Ind. August 20, 2012).*