The smell of marijuana coming from defendant’s car, never found in a search of the car, didn’t justify a search of his person while he was handcuffed and sitting on the curb. Meane v. State, 2017 Tex. App. LEXIS 5976 (Tex. App. – Houston (1st Dist.) June 29, 2017).
The evidence supported that defendant consented to the search of his cell phone. State v. Dasen, 2017-Ohio-5556, 2017 Ohio App. LEXIS 2607 (9th Dist. June 28, 2017).*