Defendant’s challenge to removal of a pill bottle from his person did not preserve a challenge to search of the pill bottle at the police station. “In any event, we conclude that Sado’s argument on appeal is without merit. Officer Dudoit’s seizure of the pill bottle from Sado’s pocket was pursuant to, and did not exceed the permissible scope of, a valid search incident to arrest. Accordingly, the pill bottle and its contents were not subject to suppression.” State v. Sado, 2017 Haw. App. LEXIS 447 (Oct. 31, 2017) (memorandum).
Summary judgment on plaintiff’s complaint against arresting officers was granted because there was probable cause for arrest. B.R. v. McGivern, 2017 U.S. App. LEXIS 22032 (6th Cir. Nov. 1, 2017).*