Defendant was stopped, and the smell of marijuana came from the car when he was stopped. A joint was seen on the console. The car was towed rather than searched at the scene. The search back at the station was not unreasonable. As an inventory, it complied with department policy. People v. Lee, 2016 NY Slip Op 07081, 2016 N.Y. App. Div. LEXIS 6990 (1st Dept. Oct. 27, 2016).
An off-duty officer at home had a car pull into his yard and shine headlights into his bedroom. He took that as potential harassment. He called an on-duty officer who found the car (late at night and no other cars on the road at all) and stopped it. The driver’s license was “barred,” and that was the arrest and it was justified. State v. Moran, 2016 Iowa App. LEXIS 1111 (Oct. 26, 2016).*