Defendant was stopped and subjected to a citizen’s arrest by Walmart security. Her purse was searched based on the arrest, and it was valid. “Thus, a search need not be incident to an arrest by law enforcement because a citizen is empowered to make the same arrest.” State v. Lee, 2017 SD 28, 2017 S.D. LEXIS 60 (May 17, 2017).
Defendant’s slow speech, bloodshot eyes, and admission of possession of marijuana was enough to search his car after his traffic stop. State v. Dewitt, 2017 Del. Super. LEXIS 239 (May 18, 2017).*