Taking gunshot residue without a warrant incident to arrest is reasonable because it disappears so fast. [The court analogizes blood alcohol, but GSR can disappear easily within minutes, simply by putting one’s hands in pockets or rubbing hands together.] State v. Boyd, 2017 W. Va. LEXIS 16 (Jan. 19, 2017) (citing plenty of authorities in n.20).
The incriminating nature of an open container is obvious. Stopping defendant alone in an isolated high crime known for gun violence justified a frisk of defendant’s car based on observations. Commonwealth v. Edwards, 2017 Mass. LEXIS 19 (Jan. 20, 2017).