E.D.Mo.: PV warrant permitted entry to place where def reasonably suspected to reside

PV warrant permitted entry into suspected residence of violator. “However, the Eighth Circuit has made clear that, provided an administrative warrant is supported by reasonable cause, it carries the same implied limited authority to enter a dwelling to effectuate an arrest as judicial warrants based upon probable cause. … As such, the parole violator’s warrant for Thorp allowed officers to enter Baker’s home, or the curtilage of Baker’s home if they had both (1) a reasonable belief that Thorp resided at Baker’s home and (2) reason to believe Thorp was present at the time the warrant was being executed. … Reasonable belief is ‘a less exacting standard than probable cause.’” United States v. Thorp, 2024 U.S. Dist. LEXIS 77475 (E.D. Mo. Apr. 29, 2024).

The search warrant for defendant’s iCloud account was particularized as to a specific time period and four possible federal crimes. “These limitations were sufficient to ensure that the executing officers would not undertake ‘a general, exploratory rummaging’ through the contents of Byrd’s accounts. Fallon, 61 F.4th at 107. And the facts attested to in the probable cause affidavit supported the finding of probable cause for a search of this scope.” United States v. Byrd, 2024 U.S. Dist. LEXIS 76693 (E.D. Pa. Apr. 26, 2024).*

The officer developed reasonable suspicion which justified extending the stop here. United States v. Trusty, 2024 U.S. Dist. LEXIS 76793 (D.N.J. Apr. 26, 2024).*

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