The fellow officer (collective knowledge) rule applies to plain view seizure of a laptop computer that was seen in plain view that the fellow officer had probable cause to believe contained child pornography. People v. Swietlicki, 2015 CO 67, 2015 Colo. LEXIS 1103 (Nov. 23, 2015).
Officer’s decision to tow defendant’s vehicle was reasonable because his vehicle was stopped on a busy highway and defendant was arrested and unable to remove the vehicle. The decision to tow the vehicle was in compliance with the Ohio State Highway Patrol’s reasonable procedures. Because the trunk was accessible from the car’s interior without a key, inventory of the trunk was reasonable. State v. Calvin, 2015-Ohio-4801, 2015 Ohio App. LEXIS 4700 (3d Dist. Nov. 23, 2015).*