A CI told the police that defendant had a warrant for his arrest. Without checking, the police arrested. There was no warrant, and the search incident to arrest is void. State v. Rodriguez, 2016 Del. Super. LEXIS 642 (Dec. 21, 2016).
The officer came upon an empty vehicle in the ditch. He opened the door and saw what later was determined to be a rum and coke in the console and an open 12 pack in the backseat. Opening the door was a search, but it was reasonable. The car was “abandoned” and he had no reasonable expectation of privacy in it. Alternatively, it was valid as an emergency search. People v. Klossner, 2016 NY Slip Op 08795, 2016 N.Y. App. Div. LEXIS 8585 (4th Dept. Dec. 23, 2016).*