This cell phone was reasonably seized under a warrant. The second warrant was issued a few weeks later, but, because of covid, the delay was reasonable. United States v. Reaves, 2022 U.S. Dist. LEXIS 43243 (D.Md. Mar. 9, 2022).
“Defendant has not shown that the errors [in the search warrant affidavit] he has identified are anything more than innocent mistakes, nor would the omission of the allegedly erroneous information affect the probable cause calculus.” United States v. Rivera-Banchs, 2022 U.S. Dist. LEXIS 42770 (W.D.N.Y. Mar. 10, 2022).*
The search warrant here was issued on probable cause. Even if it wasn’t, the good faith exception applies. United States v. Santiago, 2022 U.S. Dist. LEXIS 42977 (W.D.N.Y. Mar. 10, 2022).*