Defendant was stopped in what was thought to be a county park after midnight, but there was no proof that the park was properly established or had closing hours. Assuming that the officer committed a mistake of law, Iowa does not recognize a mistake of law under the state constitution, and the case is remanded. State v. Scheffert, 2017 Iowa App. LEXIS 423 (May 3, 2017).
No exigent circumstances justified the warrantless search of defendant’s car after he was led away in handcuffs. A paper inside the console was not in plain view. United States v. Lopes, 2017 U.S. Dist. LEXIS 67449 (D. Mass. May 3, 2017).*