W.D.N.Y.: SW for devices used for video surveillance included cell phones because apps can be used to view cameras from cell phones

In a search warrant for devices capable of use in video surveillance, a cell phone qualified because apps on phones permitted home surveillance cameras (such as Ring doorbell cams) to be viewed on cell phones. United States v. Hampton, 2024 U.S. Dist. LEXIS 64744 (W.D.N.Y. Apr. 9, 2024).

“The Court finds that the motion to suppress, (Dkts. 84, 85), should be denied for four reasons: (1) law enforcement officers had reasonable suspicion to detain Williams; (2) after her detention, officers developed probable cause to arrest Williams; (3) the search of the purse was incident to Williams’s arrest; and (4) the search of the purse and the seizure of the drugs inside were justified by the plain view doctrine.” United States v. Williams, 2024 U.S. Dist. LEXIS 64450 (W.D. Tex. Apr. 9, 2024).*

Defendant was not in custody at the time he made self-incriminating statements. He was outside his house, not detained, and told he was free to go. United States v. McLaughlin, 2024 U.S. Dist. LEXIS 65249 (W.D. Pa. Apr. 10, 2024).*

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