IA: Riley applied to a cell phone search from 2010

Defendant’s cell phone was searched in 2010, well before Riley, but a motion to suppress was filed and denied pre-Riley. The state concedes on appeal that Riley controls and attempts to get the contents of the phone in under exigent circumstances, but it can’t show any. State v. Lacey, 2015 Iowa App. LEXIS 43 (January 28, 2015).

The drugs and paraphernalia in defendant’s car were in plain view when the officer walked up to the car in a high crime area and looked in. State v. Hill, 2015 La. App. LEXIS 93 (La.App. 5 Cir. January 28, 2015).*

Defendant’s traffic stop was based on no headlights and failure to use a turn signal. When the officer got to the car he could smell burnt marijuana and saw a joint in the car. A search of the car was then justified. State v. Watson, 2015-Ohio-283, 2015 Ohio App. LEXIS 245 (9th Dist. January 28, 2015).*