D.Nev.: Parolee with traffic warrants fleeing from car and tossing keys justified parole search of car

Las Vegas officers were randomly running license plates and they ran a Saturn’s plates on a Walgreen’s parking lot after the occupant went into the store. It showed that the owner had outstanding traffic warrants and was on parole. The occupant came back out and they wanted to see if he was the owner. Seeing the police, he fled and tossed the keys. He was finally caught and detained for hours without being Mirandized. This detention might have violated the Fourth Amendment, but he was on parole and his actions gave an objective justification for the search of the car. [The court does not even mention abandonment of the keys constitutes an abandonment of the car. Most courts would hold that.] United States v. Retta, 2015 U.S. Dist. LEXIS 147187 (D.Nev. Sept. 3, 2015).*

Defendant was known to have been deported before, and he was, according to reliable CIs, involved in drug dealing again. They were looking for him on the parking lot of a Poteau, Oklahoma casino. He consented to a search of his car. They found in the trunk a sealed case of aluminum beer bottles. They opened it, and found fewer than a full case, and some of the bottles were too light. The case had excess glue on it which suggested it was a hiding place for drugs. The bottles that were too light contained methamphetamine. Even if the consent didn’t extend to the sealed container, by then there was probable cause under the automobile exception. United States v. Camargo-Chavez, 2015 U.S. App. LEXIS 18821 (10th Cir. Oct. 29, 2015).*