NJ: SW in NJ for OH crime must be litigated in OH

While New Jersey law provides that a search warrant can be issued on the request of another state for a crime in that other state, the remedy of suppression lies in the other state, not New Jersey. They also can’t get to it by seeking return of property either. In re Search Warrants of VS2 Worldwide Communs., L.L.C., 2013 N.J. Super. Unpub. LEXIS 2992 (December 20, 2013) (unpublished; but it shouldn’t be).

Defendant was followed by the police because a headlight was out, and then he made what the officer considered an evasive move by quickly turning into a driveway. The officers pulled in behind and got out to talk to the occupants, one on each side. The trial court’s finding of consent to search the car is supported by the evidence. State v. Spivey, 2013-Ohio-5581, 2013 Ohio App. LEXIS 5840 (8th Dist. December 19, 2013).*

Somebody running from car when it was stopped + furtive movement = reasonable suspicion. United States v. Harris, 2013 U.S. Dist. LEXIS 179111 (S.D. N.Y. December 20, 2013).*

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