M.D.Ga.: Dropping cell phone in flight from wrecked car is abandonment

A series of alleged crimes and other actions of the defendant was probable cause to search defendant’s phone found in his car. [There is no nexus to the crimes mentioned in the opinion, so I submit it’s wrong on this point.] But, that doesn’t matter because defendant dropped the phone in flight from his wrecked car, and that’s abandonment. United States v. Hester, 2022 U.S. Dist. LEXIS 98875 (M.D.Ga. June 2, 2022) (it’s abandonment of the car, too).

Knock-and-talk in South Carolina requires reasonable suspicion to approach the door, and here it was lacking. State v. Ferguson, 2022 S.C. App. LEXIS 60 (June 1, 2022).

The exclusionary rule does not apply to revocation of supervised release. United States v. Wright, 2022 U.S. App. LEXIS 15296 (11th Cir. June 3, 2022).*

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