OH6: Retrieving def’s purse after DUI arrest was caretaking, and plain view sustained

Defendant was arrested for DUI and placed in a patrol car. Her car was not subject to search incident. However, the officer could go back to the car to turn it off, roll up the window, and collect her purse under the caretaking function. The finding of marijuana and a pipe was thus in plain view. State v. Myers, 2014-Ohio-1039, 2014 Ohio App. LEXIS 957 (5th Dist. March 14, 2014).*

Jaywalking and dropping something is “wrongdoing” of some kind and supported a stop. State v. Duran, 2014 Utah App. LEXIS 67 (March 20, 2014).*

The officer had reason to stop defendant because he was speeding, clocked by radar, albeit in the opposite lane of I-20. United States v. Kelly, 2014 U.S. Dist. LEXIS 37220 (N.D. Ga. March 21, 2014).*