Defendant was found asleep in his car in a Walmart parking lot with his pants down after having apparently masturbated to adult porn images on his computer or phone. The discussion with the officers gave no reason to believe defendant was into child pornography or had it on his computer or phone. Thus, nothing in the affidavit for the search warrant for his devices showed probable cause to believe that child pornography would be found. State v. Norman, 2018 N.H. LEXIS 100 (July 6, 2018) (decided under state constitution and not the Fourth Amendment, but there’s no reason to believe a different outcome; it wasn’t even a close enough call for the good faith exception.)

Police received a call that defendant was harassing a woman. He ran off, leaving his car. The police got there and talked to her son; the woman and man had been dating. She believed he might have naked pictures of her daughter on his phone. She reached into his car and turned it off, and she saw his phone and took it. She looked for the pictures she’d seen before, but said they were “deeper into the phone.” She gave it to the police, and this was a private search. They didn’t ask for it. United States v. Highbull, 2018 U.S. App. LEXIS 18399 (8th Cir. July 6, 2018).