United States v. Joyner

2 Citing cases

  1. United States v. Salaman

    3:22-cr-76 (JAM) (D. Conn. Jul. 29, 2024)   Cited 1 times

    The plain view exception extends not only to objects that are themselves contraband or unlawful to possess but also to other lawfully possessed objects for which there is probable cause to believe have been used to facilitate or are evidence of the commission of a crime. See United States v. Kirk Tang Yuk, 885 F.3d 57, 79-80 (2d Cir. 2018) (applying plain view exception to allow law enforcement agents to seize two cell phones during the course of protective sweep of a bedroom where “the officers had probable cause to seize the cell phones as likely connected with [defendant's] criminal activity”); United States v. Joyner, 2019 WL 1760843, at *4 (D. Conn. 2019) (plain view exception allowed seizure of hotel key card that defendant dropped where the police had probable cause to believe that the key was for a hotel room where narcotics were stored), aff'd on other grounds, 2022 WL 68204 (2d Cir. 2022).

  2. United States v. Sanders

    No. 19-CR-125-A (W.D.N.Y. Jul. 8, 2021)

    In addition, the Government has not met its burden of proving that the seizures, if warrantless, were legal, in other words, that the seizure was “otherwise justifiable under any of the well-recognized exceptions to the Fourth Amendment's warrant requirement[.]” United States v. Joyner, No. 3:17-cr-00236 (JAM), 2019 WL 1760843, 2019 U.S. Dist. LEXIS 67996, *8-9 (D. Conn. Apr. 22, 2019). C. Whether the search warrant authorized the search and seizures at issue