Defendant came to meet the police at their request after talking to them on his cell phone. They had probable cause to believe that the phone had evidence on it. Since he came in without the phone on him, it was reasonable to believe it was in his vehicle. Facebook messages from defendant on a minor’s cell phone justified a warrant for his Facebook account. United States v. McGrain, 2021 U.S. Dist. LEXIS 59838 (W.D. N.Y. Mar. 29, 2021).
Probable cause for a forfeiture is similar to the probable cause for a search warrant. Angulo-Murrieta v. City of Yuma, 2021 Ariz. App. LEXIS 67 (Mar. 30, 2021).