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182603P.pdf   01/14/2020  United States  v.  Brent Daigle
   U.S. Court of Appeals Case No:  18-2603
   U.S. District Court for the District of North Dakota - Fargo   
   [PUBLISHED] [Shepherd, Author, with Loken and Stras, Circuit Judges] 
   Criminal case - Criminal law. The Sheriff's written affidavit and oral 
   testimony before the judicial officer were sufficient to establish 
   probable cause to issue a search warrant defendant's phone for evidence of 
   sex offenses; nor did the court err in denying his motion for a Franks 
   hearing as defendant failed to make the requisite substantial preliminary 
   showing to merit a Franks hearing; even assuming the omissions he points 
   to were intentional or made in reckless disregard of the truth, defendant 
   failed to show that the affidavit and testimony, if supplemented by the 
   additional information, would not have been sufficient to establish 
   probable cause.