Plain view is enough for seizure and suppression was unreasonable

Where the entry was authorized and the evidentiary value of drugs in plain view was apparent, seizure was lawful and the trial court erred in suppressing the plain view. People v. Gothard, 185 P.3d 180 (Colo. 2008).*

Police were called to a suspicious vehicle sitting at a gas pump for a half hour. When they arrived they found the defendant asleep with a marijuana pipe on the car console in plain view. It could be seized and was also incident to his arrest. State v. Conway, 992 So. 2d 494 (La. App. 1st Cir. 2008).*

Suspected prostitute and pimp who rented a hotel room had an expectation of privacy in the hotel room and a computer that they both used. The alleged pimp had standing in a rental car rented by his mother where he had permission to use it. United States v. King, 560 F. Supp. 2d 906 (N.D. Cal. 2008).*

Defendant’s stop was lawfully continued by reasonable suspicion to validate consent. State v. Tindall, 379 S.C. 304, 665 S.E.2d 188 (2008):

1) Tindall was nervous even after receiving the warning; 2) Tindall was driving a rental car that he had not rented; 3) Tindall was driving only one way and then dropping the car off; 4) Tindall planned on driving approximately eighteen hours in one day; and, 5) the cities involved were both “drug hubs.” We find evidence in the record to support a determination that Colegrove had a reasonable suspicion something illegal was occurring. Therefore, the search and seizure did not violate Tindall’s Fourth Amendment rights and the trial court did not err in admitting the cocaine.