WA: Leaving cell phone fleeing from a stolen car was abandonment; no SW required for abandoned property

Defendant was seen in a stolen car and the police gave chase. He bailed from the car and ran, leaving his cell phone behind. The cell phone was abandoned property, and it could be searched without a warrant. Here, the cell phone was used merely to identify the defendant. State v. Samalia, 2015 Wash. App. LEXIS 477 (March 5, 2015).

The trial court’s finding that the headlight on defendant’s car wasn’t working at the time of the stop isn’t foreclosed because the headlight was found working on the impound lot sometime later. State v. Mullican, 2015 Tenn. Crim. App. LEXIS 150 (March 4, 2015).*

Defendant’s stop for a window tint violation was objectively reasonable. State v. McNair, 2015 Tenn. Crim. App. LEXIS 151 (February 25, 2015).*