Reviewing the affidavits for the three search warrants, the court is convinced that there is still a risk of compromising the investigation, so the search warrants will remain under seal as to the potential defendant. The court recognizes the right of access; just not yet. In re Three Sealed Search Warrants, 2016 U.S. Dist. LEXIS 111838 (S.D.Tex. Aug. 17, 2016).
By the time defendant consented, the officer had reasonable suspicion to detain defendant for investigation after issuing a warning. Defendant gave an unusually elaborate reason for traveling on the highway: He was driving a rental vehicle one way, which was a common tactic of drug smugglers; he had two boxes wrapped in Christmas paper, also a common drug smuggler tactic; he had been charged with selling drugs in Florida; and he changed his story when he was asked to get out of the vehicle to receive the warning. Commonwealth v. Valdivia, 2016 PA Super 181, 2016 Pa. Super. LEXIS 458 (Aug. 19, 2016).*