“While law enforcement held the Durango for four days after the seizure before searching it pursuant to a warrant, this delay did not render the continuing seizure of the Durango unreasonable. See Donahue, 764 F.3d at 300-01 (collecting cases and holding that a five-day delay between seizure and search of a vehicle was ‘immaterial’).” United States v. Newsome, 2022 U.S. Dist. LEXIS 143466 (D.N.J. Aug. 11, 2022).
Exigent circumstances justified police entry. When they arrived at defendant’s house to investigate a domestic violence call, they heard a slap or punch inside and screaming. United States v. Hearn, 2022 U.S. App. LEXIS 22303 (6th Cir. Aug. 9, 2022).
Ninth Circuit cases say flight from a stop, even if the stop was unreasonable, is an intervening act. United States v. Daniels, 2022 U.S. Dist. LEXIS 143668 (N.D. Cal. Aug. 11, 2022).
No CoA on a Franks IAC claim where there was probable cause without the omissions. Benanti v. United States, 2022 U.S. App. LEXIS 22416 (6th Cir. Aug. 11, 2022),*