Officers spoke to defendant and he lawyered up. Then they turned to his girlfriend and talked to her getting consent. This was valid under Randolph. Defendant was right there and could have objected but didn’t. She had common authority to consent. United States v. Brown, 2017 U.S. Dist. LEXIS 15380 (E.D. Ky. Feb. 3, 2017).
The odor of marijuana coming from a car is probable cause to search it under the Fourth Amendment and the state constitution. State v. Parrott, 2017 Ind. App. LEXIS 50 (Feb. 6, 2017).*
Defendant’s property was seized from a motel room, and it was subjected to a proper inventory by the FBI. United States v. Maturano-Marin, 2016 U.S. Dist. LEXIS 183595 (N.D.Ga. Nov. 1, 2016),* adopted, 2017 U.S. Dist. LEXIS 14464 (N.D.Ga. Feb. 1, 2017).*