The state failed to prove exigent circumstances for a warrantless blood draw from the defendant. There were other officers around and a warrant could have been sought. State v. Sanders, 2017 Tex. App. LEXIS 11674 (Tex. App. – Ft. Worth Dec. 14, 2017).
The affidavit for the state search warrant showed probable cause and the good faith exception would also apply. United States v. Panky, 2017 U.S. Dist. LEXIS 205123 (N.D. Ga. Dec. 13, 2017).*
Defendant’s furtive movements in the car, which weren’t denied, justified a patdown of the defendant and a protective frisk of the car. United States v. Vaccaro, 2017 U.S. Dist. LEXIS 204625 (E.D. Wis. Dec. 13, 2017).*