OR: Seizure of cell phone was seizure of the person, but with RS

Seizure of defendant’s cell phone converted the consensual encounter into a stop, but it was with reasonable suspicion. State v. Hayes, 272 Ore. App. 1 (June 24, 2015).

The defendant here tried to extrapolate the use of GPS on somebody else’s car to show that it revealed information about the inside of defendant’s house when the GPS target came there. The court finds, however, that that did nothing of the sort. It only showed that the target car was there, not where the occupants went. United States v. Castetter, 2015 U.S. Dist. LEXIS 81041 (N.D.Ind. June 23, 2015).*

Defendant did not submit to arrest and fled, so he was not seized. He discarded and abandoned a gun in flight. United States v. Moorefield, 2015 U.S. Dist. LEXIS 81159 (W.D.Pa. June 23, 2015).*