“The search here was generally unreasonable, but it was saved by inevitable discovery. “In the present case, the Government does not contend that Hobbs had probable cause to search Defendant’s vehicle. Hobbs did not have a warrant. His search was not intended to protect himself from hazards within Defendant’s arm reach or to prevent the destruction of evidence. His search was not in pursuit of evidence related to the crime of arrest. His alleged ‘inventory search’ of the vehicle was conducted sloppily, against protocol, and seemingly not for the purpose of inventorying the vehicle. Make no mistake: but for the inevitable-discovery exception, Hobbs’s search of Defendant’s vehicle was illegal and a violation of the Constitution.” United States v. Travis, 2022 U.S. Dist. LEXIS 49324 (E.D.Wis. Mar. 21, 2022).
Where the search warrant said to search electronic devices “at said place,” it didn’t mean at the site of the seizure. United States v. Kasnetz, 2022 U.S. Dist. LEXIS 50613 (N.D.Tex. Mar. 22, 2022).*
A search warrant already being sought was inevitable discovery for this allegedly illegal search. That warrant was issued with probable cause. United States v. Potter, 2022 U.S. Dist. LEXIS 50899 (E.D.Tenn. Mar. 22, 2022).*