MD: Davis good faith saves a search incident of a cell phone 3 years before Riley was decided, even though no state case ever said so

Search incident of defendant’s cell phone two and three years before Riley was decided was in Davis good faith based on Robinson [even though no state or Fourth Circuit case had said so]. Demby v. State, 2015 Md. LEXIS 490 (July 27, 2015); Spence v. State, 2015 Md. LEXIS 491 (July 27, 2015). [How can anybody say with a straight face that Robinson’s crumpled cigarette pack equates with a smartphone for search incident purposes? This court just did.]

Nexus was established between defendant, drug activity, and a hotel room where he was desperate to get something out of the room safe. United States v. Sutherland, 2015 U.S. Dist. LEXIS 97223 (D.Me. February 12, 2015),* adopted 2015 U.S. Dist. LEXIS 97223 (D.Me. July 22, 2015).*

Minnesota’s test-refusal statute does not violate the unconstitutional-conditions doctrine by imposing a criminal penalty on a person who has been arrested for DWI and has refused to submit to a breath test. State v. Bennett, 2015 Minn. App. LEXIS 55 (July 27, 2015).*