FL3: Neighbor’s call of a broken back window brought police who suspected burglary; entry was justified

Defendant’s neighbor called the police because of a broken back window strongly suggesting a burglary. An officer arrived with a dog, and when no one answered, he sent in the dog. Following the dog, no people were found but the dog alerted at the bathroom door for drugs. In the shower the officer found marijuana plants. The entry and the drug find was reasonable under all the circumstances. State v. Yee, 2015 Fla. App. LEXIS 15198 (Fla. 3d DCA Oct. 14, 2015).

Two civil cases over alleged illegal searches in the Districts of Massachusetts and New Hampshire are not sufficiently complex or related to require consolidation. In re Omran Litig., 2015 U.S. Dist. LEXIS 140103 (M.D.L. Oct. 9, 2015).

Defendant was excessively nervous when stopped. The officer called for a drug dog, which took seconds and did not itself extend the stop. While the officer was completing the paperwork tasks and waiting for clearance of the DL (which finally came), defendant was moving around in the car, which concerned the officer enough to turn on the spotlight but not get out of the car. Back at the car window, the officer inquired into the nervousness, and defendant admitted having marijuana in the car and produced a bag. The stop and its extension were reasonable. State v. Hays, 2015 Ida. App. LEXIS 97 (Oct. 14, 2015).