Monitoring a lawfully placed GPS device on a car is not a separate search. It is lawful under Knotts, well before CSLI. United States v. Howard, 2021 U.S. App. LEXIS 15856 (11th Cir. May 27, 2021).
The affidavit for the warrant here clearly showed probable cause to search the apartment. “Thus, Defendant’s attempt to counter that information has no bearing on whether the search warrant was supported by probable cause.” United States v. Donaldson, 2021 U.S. Dist. LEXIS 99586 (W.D. N.Y. May 26, 2021).*
“While the victim may have been uncooperative, the victim was not confidential, unknown or anonymous.” A crime victim’s veracity isn’t treated the same as a CI. United States v. Berry, 2021 U.S. Dist. LEXIS 99601 (M.D. Ala. May 26, 2021).