MO: Trial court erred in suppressing car search incident without also considering automobile exception

The trial court erred in applying the search incident doctrine to defendant’s vehicle search and suppressing when the state also argued the automobile exception. Remanded for consideration of that issue, too. State v. Walker, 2015 Mo. App. LEXIS 501 (May 5, 2015).

A coram nobis petitioner who’s already litigated and relitigated his search and seizure claim can’t do it here without “new evidence,” and he doesn’t have anything new to present. Jefferson v. State, 2015 Tenn. Crim. App. LEXIS 332 (May 6, 2015).

Where defendant was suspected of ongoing harassment by use of the mail, the fact he allegedly mailed an IED eleven months earlier was not stale for purposes of a search warrant for his house looking for parts of the IED as a part of the harassment investigation. United States v. Shrader, 2015 U.S. Dist. LEXIS 59193 (N.D. Okla. May 6, 2015).*