Defendant drove up to a house in the process of a drug raid. Eight people were in custody. Defendant was stopped when he got to the door, and he was frisked and a gun was found. The search was valid under Michigan v. Summers. Shotts v. State, 2016 Ind. App. LEXIS 126 (April 27, 2016).
The district court found that the decision to seek a search warrant for defendant’s cell phone was not prompted by a prior illegal search of the cell phone. Thus, the independent source rule applies. United States v. Barron-Soto, 2016 U.S. App. LEXIS 7569 (11th Cir. April 26, 2016).