N.D.Ill.: Passenger in car had standing to challenge search of his own bag during stop

Defendant had standing to challenge the search of his own bag when he was riding in someone else’s car. The protective sweep of the car, however, was based on reasonable suspicion and finding an ammunition box was plain view. United States v. Blackman, 2023 U.S. Dist. LEXIS 81861 (N.D. Ill. May 10, 2023).*

The seizure of defendant’s cell phone lacked a reasonable basis or probable cause, and the subsequent warrant for it was thus suppressed. United States v. Crutchfield, 2023 U.S. Dist. LEXIS 80699 (D. Minn. Mar. 21, 2023),* adopted, 2023 U.S. Dist. LEXIS 80461 (D. Minn. May 9, 2023).*

There was probable cause for defendant’s arrest for child sex trafficking, so the warrantless seizure of his cell phone incident to arrest was reasonable. United States v. Midder, 2023 U.S. Dist. LEXIS 80685 (D. Neb. Apr. 20, 2023).*

Pre-Carpenter CSLI that became part of a wiretap order was not excludable. United States v. Cooper, 2023 U.S. App. LEXIS 11435 (3d Cir. May 10, 2023).*

Pre-Carpenter CSLI to find a missing victim was not excludable. State v. Adams, 2023 La. App. LEXIS 790 (La. App. 5 Cir. May 10, 2023).*

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