D.Conn.: Unreasonable delay in getting SW for cell phone defeats GFE

Where the officers impermissibly delayed obtaining a search warrant for defendant’s cell phone, the good faith exception does not apply. The initial seizure of the phone was valid because it was left at a crime scene. United States v. Tisdol, 2021 U.S. Dist. LEXIS 107821 (D.Conn. June 9, 2021).

Defendants’ claim a protective sweep was unreasonable isn’t preserved. Even if it was, it would be harmless error. United States v. Mills, 2021 U.S. App. LEXIS 17140 (3d Cir. June 9, 2021).*

Redacting the CI’s information here was shown necessary to protect her. Probable cause was clearly shown. People v. Bryant, 2021 NY Slip Op 03603, 2021 N.Y. App. Div. LEXIS 3686 (2d Dept. June 9, 2021).*

Old information about meth possession was properly factored into a warrant application for a grow operation. Moreover, the good faith exception applies. United States v. Sutton, 2021 U.S. Dist. LEXIS 107226 (W.D. Ky. June 7, 2021).*

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