NM: Calls to murder victim’s cell phone just before murder was PC to get CSLI on the phone

A shooting victim made and received cell phone calls to his phone and the calls were not in the contacts list 30 minutes before the victim was found dead. This was probable cause for data about that caller including the CSLI around the time of the shooting. The trial court erred in suppressing the CSLI. State v. Price, 2020 N.M. LEXIS 23 (Aug. 3, 2020).

The inventory of defendant’s vehicle was not unreasonable or improper. It followed the department’s policy. Defendant’s argument that inventory was a way to circumvent a Gant search incident is misplaced. Lesser intrusive measures of attempting to get someone else to come and get the car wasn’t constitutionally required. United States v. Love, 2020 U.S. Dist. LEXIS 138464 (S.D. Ind. Aug. 4, 2020).*

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