Defendant’s former girlfriend found child pornography on his computer. She took the computer to the Reno sheriff’s office, and the police there had her show them what she did and go no farther. This was admitted by the government to be a search, but it was reasonable because of her prior search under Jacobsen. The court rejected the “common-law trespassory test” from United States v. Jones, 565 U.S. 400 (2012), applies and requires suppression here. United States v. Phillips, 2022 U.S. App. LEXIS 11678 (9th Cir. Apr. 29, 2022).
The specifics of defendant’s particularity challenge was waived by not raising it below. The warrant was valid on all grounds, so the good faith exception doesn’t even have to be applied. Eyewitnesses connected defendant’s car to a crime, so there was probable cause for its search and seizure. State v. Hudgen, 2022 R.I. LEXIS 35 (Apr. 27, 2022).*
Defendant’s challenge to the warrant affidavit as lacking probable cause is conclusory and doesn’t warrant a hearing. In any event, the good faith exception applies. United States v. Cruz-Vega, 2022 U.S. Dist. LEXIS 77682 (W.D.N.Y. Apr. 28, 2022).*