TN: In a counterfeiting investigation with consent, computer, scanner, and color printer are obviously instrumentalities of the crime

Defendant was arrested at home for passing three counterfeit $10 bills at McDonald’s restaurants. His roommate consented to a search of the common area, and the original $10 bill was found with computer equipment. Since computers, scanners, and color printers are now used to counterfeit money, the evidentiary value of the computers was immediately apparent justifying their seizure. A later valid search of the computers turned up child pornography. State v. Wendland, 2011 Tenn. Crim. App. LEXIS 82 (January 31, 2011).*

Probable cause was shown for the search warrants in this case by controlled buys where the CI was told to come to the buildings searched. As to a Franks challenge, the omitted information was not at all material to the finding of probable cause. United States v. Manzanares, 2011 U.S. Dist. LEXIS 10742 (D. Minn. January 5, 2011).*

Defendant was arrested in his doorway, and the entry was justified by outstanding warrants for his arrest. He got into an altercation with the officers, and that led to a protective sweep of the premises where two others were found. The officers did not have to have the arrest warrants in hand; they heard about them from dispatch. The protective sweep led to a further consent search. United States v. Perez, 2011 U.S. Dist. LEXIS 10721 (C.D. Cal. January 20, 2011).*