E.D.Mich.: Undercover officers entering public areas of a strip club as customers not a search

First undercover officers and then other officers entered plaintiff’s strip club to investigate alleged misdeeds inside. No warrant was needed under Macon because the parts of the club entered by the officers were open to the customers. ABECE Operating v. City of Detroit, 2017 U.S. Dist. LEXIS 80163 (E.D. Mich. May 25, 2017).

The odor of alcohol coming from defendant after his automobile accident essentially was enough to have breath test. (Other factors were discussed, but they don’t amount to much.) State v. Barger, 2017-Ohio-4008, 2017 Ohio App. LEXIS 2029 (2d Dist. May 26, 2017).*