CA6: SW for safe 5 days after seizing it was a reasonable delay

The seizure of defendant’s safe was with probable cause. Getting a warrant to search it five days later was reasonable. United States v. Grundy, 2025 U.S. App. LEXIS 1526 (6th Cir. Jan. 22, 2025).*

The totality of circumstances showed probable cause for search warrants, even with the misstatement about positive identification. Other factors supported probable cause, such as witness descriptions, defendant’s relationship with the victim, his movements captured on surveillance footage, and his efforts to establish an alibi. Commonwealth v. Kimmel, 2025 PA Super 18 (Jan. 24, 2025).*

The officer did not stop and seize defendant because defendant stopped on his own. Their encounter thereafter was by consent. State v. Edmonson, 2025-Ohio-176 (5th Dist. Jan. 23, 2025).*

Defendant’s Franks challenge here fails for lack of materiality. United States v. White, 2025 U.S. Dist. LEXIS 12006 (W.D. Ky. Jan. 23, 2025).*

There was probable cause for the search warrant of defendant’s house. United States v. Woodard, 2025 U.S. Dist. LEXIS 11846 (N.D. Ohio Jan. 23, 2025).*

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