Defendant moved to suppress, but he did not claim a reasonable expectation of privacy in the place searched or the things seized, so he cannot prevail. [Note I didn\u2019t say \u201cstanding.\u201d] United States v. Rogers, 2013 U.S. Dist. LEXIS 173175 (D. Minn. August 29, 2013).*<\/p>\n
One Beckman had possession of defendant\u2019s cell phone and he showed child pornography pictures on it to a police officer who then took the phone for a search warrant. The initial seizure was private, and the showing to the police was not unreasonable. United States v. Rasmussen, 2013 U.S. Dist. LEXIS 172437 (D. Minn. December 6, 2013),* R&R 2013 U.S. Dist. LEXIS 172880 (D. Minn. October 9, 2013).*<\/p>\n
If the search in this case were based on inventory, defendant would win, but it can be justified by search incident and it\u2019s valid. United States v. Vance, 2013 U.S. Dist. LEXIS 172187 (E.D. Mo. November 7, 2013), adopted 2013 U.S. Dist. LEXIS 171493 (E.D. Mo., Dec. 5, 2013).*<\/p>\n","protected":false},"excerpt":{"rendered":"
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