Open container violation in NYC supported a search incident to an arrest. The officer was first going to issue a summons but did a patdown and arrested when the gun was found. United States v. Diaz, 2017 U.S. App. LEXIS 6579 (2d Cir. April 18, 2017).
Defendant’s “multifaceted” attack on the search warrant at issue fails because there is probable cause. United States v. Hollis, 2017 U.S. Dist. LEXIS 58110 (W.D.Ky. April 17, 2017).*