D.Haw.: The nature of Hawai’i being what it is, it was not unreasonable for Postal Inspectors to divert a package to Honolulu for search

Defendant was suspected of shipping meth from Oahu to Kauai, Hawai’i. He flew out one morning to Honolulu and was returning that night. Officers waited in the airport for his return. They had two warrants for his arrest. When he landed, they arrested him on the warrants and conducted a search incident that revealed a USPS shipping receipt. Postal Inspectors looked at the sorting facility for the package, likely to have been on the same plane and found it. The nature of the Hawaiian Islands being what it is, Postal Inspectors only had an office in Honolulu, and the package had to be shipped there for more resources and to apply for a federal search warrant. The search incident producing the postal receipt was valid. The delay in the package delivery was reasonable under all the circumstances. United States v. Conwill, 2016 U.S. Dist. LEXIS 36395 (D.Haw. March 21, 2016).

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