Fifteen months to review a cell phone search \u201cwas accomplished in a reasonable amount of time. Although a review period of fifteen months is \u2018certainly not brief,\u2019 it was not unreasonably long considering \u2018the challenges of searching ESI from electronic devices\u2019 and the Government’s multiple attempts to extract the data in a reviewable format. United States v. Daskal, 676 F. Supp. 3d 153, 178-79 (E.D.N.Y. 2023) (finding that a review period of 23 months was reasonable). Moreover, courts in this Circuit regularly find that similarly lengthy review periods are reasonable. \u2026\u201d United States v. Fofanah, 2025 U.S. Dist. LEXIS 74575 (S.D.N.Y. Apr. 18, 2025).<\/p>\n\n\n\n
Smell of marijuana from defendant\u2019s car was probable cause for an automobile exception search. United States v. Warfield, 2025 U.S. Dist. LEXIS 73725 (W.D. La. Apr. 1, 2025),* adopted, 2025 U.S. Dist. LEXIS 72831 (W.D. La. Apr. 16, 2025).*<\/p>\n\n\n\n
No Franks hearing: \u201cThis time, though, Hitchcock misreads the affidavit. It did not purport to state that [Officer] Jousma had seen the drugs. It stated only that Jousma \u2018observed Hitchcock do what appeared to be a hand to hand drug transaction.\u2019\u201d Probable cause was shown. United States v. Hitchcock, 2025 U.S. App. LEXIS 9252 (6th Cir. Apr. 17, 2025).*<\/p>\n","protected":false},"excerpt":{"rendered":"
Fifteen months to review a cell phone search \u201cwas accomplished in a reasonable amount of time. Although a review period of fifteen months is \u2018certainly not brief,\u2019 it was not unreasonably long considering \u2018the challenges of searching ESI from electronic … Continue reading