Multiple cell phones in the car in a cross-country drug transportation enterprise was probable cause for searching the phones with a search warrant. “The Court finds that these facts, considered in the totality of the circumstances, provided the issuing magistrate with a substantial basis for concluding that probable cause existed. The inclusion of the substantial amount of contraband, evidence of cross-country drug transportation, multiple cell phones, and the affiant’s significant law enforcement experience are particularly persuasive. Because the four corners of the affidavit contained sufficient content to provide the magistrate with a substantial basis for concluding that probable cause existed to search Mr. Green’s cell phones, the motion to suppress is denied.” United States v. Green, 2020 U.S. Dist. LEXIS 4421 (W.D. Ky. Jan. 9, 2020).

2255 CoA granted on whether defendant “was prejudiced by his trial counsel’s failure to seek suppression of the search warrant issued to ‘any Sheriff of the State of Alabama’ under Ala. Code § 15-5-5.” Smith v. Comm’r, 2020 U.S. App. LEXIS 826 (11th Cir. Jan. 9, 2020).* We don’t have the pleadings, but this doesn’t seem to square with Virginia v. Moore.