E.D.Okla.: Lack of nexus to cell phone saved by GFE

The affidavit for the search warrant for defendant’s phone didn’t show nexus, but it was still relied upon in good faith. R&R rejected. United States v. Langford, 2022 U.S. Dist. LEXIS 55162 (E.D.Okla. Mar. 28, 2022).

Sounds and observations of what might be going on inside showing violence might be occurring is exigency for a warrantless entry. State v. Rowley, 2022-Ohio-997, 2022 Ohio App. LEXIS 899 (12th Dist. Mar. 28, 2022).*

It was not reasonable for the officer to conclude that defendant violated the traffic law before making the stop. The state injected a new theory on appeal not raised below, and it’s waived. People v. Holiman, 2022 Cal. App. LEXIS 250 (1st Dist. Mar. 28, 2022).*

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