Your Phone at the Border: Fourth Circuit Says Manual Searches Require No Suspicion
United States v. Belmonte Cardozo, No. 25-4239 (4th Cir. July 13, 2026) TL;DR A traveler arriving at Washington Dulles International Airport from Bolivia was stopped for a customs inspection. A CBP officer asked him to unlock two iPhones. He complied. The officer manually opened the photo galleries, navigated to the phones’ hidden-photo folders, and discovered illegal images within approximately two minutes. The defendant moved to suppress, arguing that the significant privac
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The Stop Behind the Stop: Eighth Circuit Upholds Narcotics Investigation Built Around a Pretext Traffic Stop
United States v. Drayton, No. 24-2519 (8th Cir. July 13, 2026) TL;DR Police investigating a suspected methamphetamine trafficker watched him engage in what appeared to be multiple drug transactions throughout the day. Later, officers saw another person place a bag into his vehicle. An officer involved in the surveillance followed the suspect onto the interstate, observed him hit the fog line three times, and initiated a traffic stop. While the stopping officer was still proce
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When a “Voluntary Encounter” Becomes a Seizure: 4th Cir. Suppresses Gun After Officers Blocked Parked Car
United States v. Williams, No. 24-4512 (4th Cir. July 7, 2026) TL;DR Police received an anonymous 911 report that a light-skinned male with braids was sitting in a white Mercedes near an apartment-complex pool and “appears to be making drug transactions.” Two officers responded in separate marked police vehicles. The officers intended to make a voluntary encounter. But instead of parking in available spaces, they simultaneously stopped their patrol vehicles in the roadway, wi
9 min read