Defendant’s keys were on the ground under him when he was arrested face down and handcuffed behind his back. They were seen when he was lifted up to stand. They were seized incident to his arrest, and inserting the key into a lock to see if it works is not a search under established precedent in this circuit. United States v. Harvey, 2017 U.S. Dist. LEXIS 147021 (E.D. Ky. Sept. 11, 2017).
Reasonable suspicion: strong smell of air fresheners in the vehicle, defendant’s statements about an uncle’s illness and defendant’s own whereabouts the night before were vague and conflicting, and the location of the traffic stop was along a stretch of interstate that was known by the deputy to be a drug trafficking corridor. Taylor v. State, 2017 Ga. App. LEXIS 416 (Sept. 14, 2017).*