Defendant’s car was pulled over for a missing license plate and overtinting. The “plain” smell of marijuana was evident, and he was removed from the car for a patdown. The patdown revealed heroin by plain feel, which was valid. The car was removed for inventory. There was enough to search it on the street, and that continued to the inventory. The search warrant for the house was based on two months of information. United States v. Williams, 2016 U.S. App. LEXIS 23986 (6th Cir. May 10, 2016).
Defense counsel wasn’t ineffective for not challenging the government’s peer-to-peer entry into defendant’s computer files. Smith v. United States, 2017 U.S. Dist. LEXIS 182930 (W.D. La. Sept. 15, 2017).*