MI: Leaving backpack in car def was ordered out of was a lack of standing when the car got searched

Defendant lacked standing in his own backpack in a vehicle that was subject to search for impoundment for having no valid LPN under People v. LaBelle, 478 Mich. 891, 732 N.W.2d 114 (2007). The motion to suppress was properly denied. The backpack was in his lap when the car was stopped, and he got out and left it on the floorboard. People v. Mead, 2017 Mich. App. LEXIS 1252 (Aug. 8, 2017).

In the investigation of the murder of defendant’s wife on a military base, defendant wasn’t in custody for Fourth or Fifth Amendment purposes when interrogated. United States v. Walker, 2017 U.S. Dist. LEXIS 123766 (D. Haw. Aug. 3, 2017).*

Supported by the video of the stop, the court finds the officer did not have reasonable suspicion to continue questioning of defendant outside the incidence of the traffic stop. There is no de minimus exception to the reasonable suspicion requirement. The gun is suppressed. United States v. Clark, 2017 U.S. Dist. LEXIS 124295 (D. N.J. Aug. 7, 2017).*