M.D.La.: Later suppression of drugs that led to indictment and finding more drugs on arrest doesn’t suppress the second find

Defendant was subjected to a search and arrested with drugs. He was indicted on that. When executing the arrest warrant, officers found defendant with more drugs. After that, defendant succeeded in suppressing the evidence in the first case that led to the indictment and arrest and finding of the second drugs. Those, however, are not suppressed because there was independent probable cause and the officers were executing the arrest warrant in good faith. United States v. Reed, 2016 U.S. Dist. LEXIS 169283 (M.D.La. Dec. 7, 2016).

There is no reasonable expectation of privacy in trash containers left out on the street for collection. The trash pull here led to probable cause for a search of the house. State v. Guardarrama, 2016 Del. Super. LEXIS 634 (Dec. 14, 2016).*