E.D.Mich.: Sex trafficking a minor in a hotel room was exigency for warrantless entry on PC

Defendant rented his hotel room under a known alias of his for which he had an ID card. That gave him standing. The exigency of sex trafficking a minor justified the officer’s warrantless entry, and it’s apparent there was probable cause for obtaining a search warrant later without resort to what was found in the room. United States v. Hudson, 2017 U.S. Dist. LEXIS 3096 (E.D.Mich. Jan. 10, 2017).

Crossing over the fog line is not necessarily an offense. “Regardless, the State has misconstrued Smith. In that case, our supreme court held that crossing over a fog line, unlike crossing over a double yellow line, ‘does not create an offense that always may be discerned simply by observation.’ Smith, 484 S.W.3d 393 at 403. The court specifically rejected that an officer’s observing a motorist cross over a fog line gives the officer probable cause to stop the vehicle and held that ‘the totality of the circumstances may provide a reasonable suspicion sufficient to initiate a traffic stop to investigate the possible violation.’ Id. at 410.” Summarily denying the motion to suppress was error. State v. Eskridge, 2017 Tenn. Crim. App. LEXIS 24 (Jan. 17, 2017).*