MA: PC was shown for cell phone search on admission there were timely videos that could help explain

There was probable cause for a search warrant for photos and videos on defendant’s cell phone in a home invasion case based on all the evidence in the case to that point and, pointedly, admission there were videos on the phone, and that could tell who confederates might be as well as where she was. Commonwealth v. Fencher, 95 Mass. App. Ct. 618 (July 17, 2019).

Defendant’s claim that the government didn’t provide discovery to enable him to properly challenge the search in his case was waived by his guilty plea. Henton v. United States, 2019 U.S. Dist. LEXIS 118526 (E.D. Mich. July 17, 2019).*