The Seventh Circuit finds that the border search exception was not affected by Riley and Carpenter such that a search warrant is required for search of electronics at the border. United States v. Wanjiku, 2019 U.S. App. LEXIS 8154 (7th Cit. Mar. 19, 2019).
Defendant’s Franks claim on appeal was waived by failure to present it to the trial court. The credibility determination of the trial court on the suppression issue is binding on this court. People v. Fitch, 2019 NY Slip Op 01973, 2019 N.Y. App. Div. LEXIS 1971 (4th Dept. Mar. 15, 2019).*
Lack of insurance papers justified extending the stop, but finding a nail file that could have been just rusty and not with drug residue didn’t justify a search of the car. The inventory search wasn’t justified. State v. Frost, 2019 Del. Super. LEXIS 134 (Mar. 13, 2019).*