D.Minn.: Merely unlocking cell phone without looking in it is not a search

“[U]sing a passcode to unlock Defendant’s cellphone without exploring the contents of the phone does not constitute a search under the Fourth Amendment.” United States v. Jackson, 2021 U.S. Dist. LEXIS 202192 (D.Minn. Oct. 20, 2021).

The protective sweep was reasonable and based on claims of a man inside with a gun. United States v. Duncan, 2021 U.S. Dist. LEXIS 201951 (E.D.Wis. Oct. 20, 2021).*

Defendant kind of fit the description of the person wanted, but when he made furtive movements to avoid police contact, it ripened to reasonable suspicion. United States v. Thomas, 2021 U.S. Dist. LEXIS 202246 (S.D.Fla. Oct. 5, 2021).*

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