S.D.N.Y.: Video of def and cell phone at scene of crime is PC for phone

Defendant with his cell phone in hand was at the scene of a shooting as shown by surveillance video. That’s probable cause for the phone. United States v. King, 2022 U.S. Dist. LEXIS 53647 (S.D.N.Y. Mar. 24, 2022).

When the facts of a motion to suppress are based entirely on police reports, a hearing is not required. People v. Fontaine, 2022 VI SUPER 37U, 2022 V.I. LEXIS 28 (Mar. 18, 2022).

2255 claim that DNA sample was obtained in violation of Fourth Amendment is Stone barred. Nicholson v. Bauman, 2022 U.S. App. LEXIS 7871 (6th Cir. Mar. 24, 2022).*

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