GA: Def was detained and frisked for drugs, and view of text messages [pre-Riley] was reasonable based on drug dealing

Defendant first fled from police from a stop for driving with no headlights. The officer broke off the chase then went to the address the car was registered to and found it. Defendant was there with another, and he was detained and frisked and drugs for sale, paraphernalia, and cell phones were found on him. An officer looked through the text messages without a warrant [pre-Riley], but a search warrant was later obtained. There was a rational basis for concluding there would be evidence on the cell phone without regard to the view of the text messages. Glispie v. State, 2015 Ga. App. LEXIS 748 (Nov. 20, 2015).

Defendant called the police as a crime victim, and two officers arrived and talked to him. He was not in custody, and he consented to a search. State v. Cuddy, 2015 Tenn. Crim. App. LEXIS 940 (Nov. 23, 2015).*

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