MO: Police could arrest def at motel and wait until next day to get into his room for nonpayment of rent

Defendant was first stopped because housekeeping at the hotel he was staying in saw dope in the room and management locked him out and called the police. He was stopped on foot and it was discovered there was a warrant for him. The impoundment and inventory of defendant’s car was reasonable because he was in custody and the actual owner was unknown. Also, it wasn’t shown to be pretextual. The police waited until his time in the room expired the next day and they entered and seized his stuff. The entry into the room was reasonable because he was no longer a guest. State v. McDowell, 2017 Mo. App. LEXIS 196 (March 21, 2017).

Defendant failed to demonstrate that defense counsel’s failure to pursue a suppression motion of his computer was either ineffective or prejudicial. There was clearly probable cause to seize the computer for internet fraud, and a search warrant for the computer would have issued as a matter of course. Almahdi v. AG of N.Y., 2017 U.S. Dist. LEXIS 41527 (S.D. N.Y. March 22, 2017).*

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