OH9: Nine air fresheners on mirror and one on each air vent was RS

Defendant had nine air fresheners hanging from the rearview mirror and one over every air vent. That was reasonable suspicion to utilize a drug dog during the computer checks and then another officer running a dog around the car while that was going on. It did not extend the stop [but there was raasonable suspicion anyway]. State v. Brooks, 2016-Ohio-7025, 2016 Ohio App. LEXIS 3887 (9th Dist. Sept. 28, 2016).

The merits of defendant’s search IAC claim was rejected on appeal and can’t be brought in a 2255. Corsi v. United States, 2016 U.S. Dist. LEXIS 132481 (W.D.N.C. Sept. 26, 2016).*

Defense counsel was not ineffective for challenging the search of his cell phone [defendant wasn’t clear as to whether it was his or a co-defendant’s]. In any event, the search was valid and the time it happened under Fourth Circuit law overruled in Riley. It was the law, however, through the appeal, too. Fernandez-Gradis v. United States, 2016 U.S. Dist. LEXIS 133498 (W.D.N.C. Sept. 27, 2016).*