D.Minn.: Warrant for ion scan of defendant’s door and door frame was issued on PC

Because a drug dog wouldn’t alert to fentanyl, the government showed probable cause on the totality of circumstances for an ion scan of defendant’s apartment door for traces of fentanyl. Warrants for ion scans have been approved in other cases. United States v. Branch, 2023 U.S. Dist. LEXIS 74845 (D. Minn. May 1, 2023), R&R 2023 U.S. Dist. LEXIS 75132 (D. Minn. Mar. 16, 2023).

State habeas petitioner had his full and fair opportunity to litigate the search issue in state court, so habeas relief is denied on that ground. Morris v. Shinn, 2023 U.S. Dist. LEXIS 74415 (D. Ariz. Apr. 28, 2023).*

Plaintiff was arrested for one case and then transferred to another Chicago police precinct for another investigation. That did not require separate probable cause (although it’s apparent there was). Crowder v. Barrett, 2023 U.S. App. LEXIS 10461 (7th Cir. Apr. 28, 2023).*

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