DC: Failing to file a motion to suppress is waiver of the issue

Defendant never filed a motion to suppress prior to trial, so the search and seizure claim is waived. Proctor v. United States, 2017 D.C. App. LEXIS 55 (March 16, 2017), amended 2017 D.C. App. LEXIS 331 (Oct. 26, 2017).

The passenger didn’t have standing for the search of the car. Reasonable suspicion developed from numerous plastic baggies on the console. The 25 minute wait for the drug dog wasn’t unreasonable. State v. Brown, 2017 W. Va. LEXIS 164 (March 13, 2017) (memorandum).*

Eight factors, innocent in themselves, were recounted as adding up to reasonable suspicion on the totality. United States v. Johnson, 2017 U.S. Dist. LEXIS 33859 (D.Neb. March 9, 2017).*

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