This inventory was shown to be valid despite the argument that defendant’s wife could have been called to get the car. No Fourth Amendment case says that’s a requirement. United States v. Crane, 2015 U.S. Dist. LEXIS 8448 (N.D. Iowa January 26, 2015).

On the totality, defendant’s consent on video was shown by the government to be voluntary. He was smiling during the encounter, and he read a consent form in Spanish that said he had a right to refuse consent. United States v. Guevara-Miranda, 2015 U.S. Dist. LEXIS 9226 (W.D. La. January 20, 2015).*

Stopping defendant after he pulled into another person’s driveway at night was unreasonable. The area was not a high crime area, the officer was not responding to a call, and he had no suspicion of any traffic infraction or any other criminal activity. The community caretaking / emergency aid exception to the Fourth Amendment warrant requirement did not apply because there was no evidence that the officer had any reason to believe defendant was in imminent harm. State v. Dixon, 2015-Ohio-208, 2015 Ohio App. LEXIS 181 (11th Dist. January 26, 2015).*