NY Albany: SW’s problematic time limits support severability

The time limits on the scope of the warrant are problematic, but severable. People v. Williams, 2023 NY Slip Op 23137, 2023 N.Y. Misc. LEXIS 2165 (Albany Co. May 8, 2023).*

In a sex trafficking case, probable cause was shown for defendant’s cell phone as an instrumentality of the crime. The warrant was limited to evidence of sex trafficking. United States v. Jackson, 2023 U.S. Dist. LEXIS 79545 (E.D. Wis. May 8, 2023).*

The good faith exception applies. The executing officers objectively believed the warrant to be valid. They were familiar with the property, had long history of responding to calls at that location, exhibited no confusion as to the property to be searched, and searched only the camper, two pickup trucks, and two trailers identified in the search warrant. United States v. Wilson, 2023 U.S. App. LEXIS 11140 (5th Cir. May 5, 2023).*

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