The inventory here wasn’t complete because defendant’s cell phone wasn’t in the inventory and apparently left behind. [Now that’s ironic.] A gun and ammunition were. Because they are dangerous instrumentalities, that makes the inventory reasonable. “It is not obvious to the court that suppression is the appropriate remedy to address a trooper’s failure to complete an inventory search with the degree of thoroughness required by the PSP field regulation. And, Shirk has not cited any authority for the proposition that items seized during an inventory search that fails to meet the standards set by the PSP should be suppressed.” United States v. Shirk, 2022 U.S. Dist. LEXIS 4689 (M.D.Pa. Jan. 10, 2022).
An obvious typo in a date is not reckless under Franks. In haste to complete a search warrant affidavit, two days of information had been omitted. This was not negligent or reckless for Leon purposes, and the good faith exception applies. Moreover, the omissions worked to defendant’s benefit. It was not so lacking in probable cause that the good faith exception should not apply. United States v. Medearis, 2022 U.S. Dist. LEXIS 3500 (D.S.D. Jan. 7, 2022),* adopting 2021 U.S. Dist. LEXIS 249597 (D.S.D. Nov. 17, 2021).