Drugs on an occupant of a vehicle supports a search of the trunk and other compartments. United States v. Brown, 2017 U.S. App. LEXIS 1720 (4th Cir. Jan. 31, 2017).
Defendant appeals a supervised release search term that does not require reasonable suspicion. Under plain error review, the court can’t say that the error is plain in light of the fact that Samson and this court have upheld suspicionless probation search terms. United States v. Erwin, 2017 U.S. App. LEXIS 1775 (5th Cir. Feb. 1, 2017).*