Redacted search warrant application showed probable cause even with redactions. United States v. Rivers, 2021 U.S. Dist. LEXIS 104195 (E.D. Mich. June 3, 2021).
The officer had called for a tow truck for defendant’s car and an inventory was inevitable, the decision already having been made. Therefore, inevitable discovery applies. United States v. Brown, 2021 U.S. App. LEXIS 16747 (4th Cir. June 4, 2021).
Defendant objectively consented to the search of her cell phone. The officer “testified that he asked ‘Can I search your phone?’ to which Defendant nodded and handed her phone to him. Trooper Ford testified that he did not qualify his request by asking to search Defendant’s email only. The object of interest in this search was Defendant’s phone, not Defendant’s email. Accordingly, I find that Trooper Ford did not exceed the scope of Defendant’s consent when he examined photos contained on her phone.” United States v. Ramos-Colon, 2021 U.S. Dist. LEXIS 104097 (E.D. Pa. June 3, 2021).*