Defendant was reported to have pointed a gun at a woman, and the police showed up. The gun was suppressed as far as his involuntary consent was concerned, but the state’s reference to the gun was not cause for a mistrial because seeing it happened before the illegal search. Commonwealth v. Baldwin, 2017 PA Super 95, 2017 Pa. Super. LEXIS 239 (April 10, 2017).
The defendant and his vehicle were linked by a tip off surveillance footage on TV to be involved in an arson two years earlier. Further investigation developed to link him to the arson. Defendant was then pulled over in an otherwise legitimate traffic stop and the vehicle looked in. The officer’s motivation to look in the vehicle was irrelevant, and he’d already developed enough cause to seek a warrant for the vehicle, so he had an independent source for searching the vehicle before the alleged illegal stop. United States v. Williams, 2017 U.S. Dist. LEXIS 53584 (W.D. N.Y. April 6, 2017).*