United States v. Demontae Bell (7th Cir. June 2019)

The Court held that the officer violated the defendant's Fourth Amendment right by opening his phone after the defendant's arrest, where the officer saw a picture of a firearm, but affirmed the district court's denial of the motion to suppress under the independent source doctrine, since the officers had already seen the picture on another occasion, and since there was probable cause notwithstanding the tainted picture.
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