The information in a drug search warrant was six months old. No reasonable officer would believe it showed probable cause, despite a magistrate signing off on it. It is “so lacking” in its showing that the good faith exception does not apply. United States v. Suong, 2022 U.S. Dist. LEXIS 178494 (D. Mass. Sep. 30, 2022).
Being ordered out of one’s car during a traffic stop is not unreasonable. United States v. Pullen, 2022 U.S. Dist. LEXIS 178249 (E.D. Cal. Sep. 29, 2022).*
Defendants were convicted of wire fraud involving pharmaceutical returns. The search warrant here was issued in 2011 for information found on computers which the defendants already told the government it had all the pertinent records. The records sought were found on a hard drive, and the warrant was sufficiently particular. Moreover, the good faith exception applies. There was also a 2014 warrant involved in the suppression hearing, and it isn’t discussed on appeal, so it is abandoned. United States v. Fallon, 2022 U.S. App. LEXIS 27404 (3d Cir. Sep. 30, 2022).* When the government can show a reason to go back after execution of a warrant, there’s no reason they can’t get another if they can show probable cause.