Defendant consented to a search of his pockets, and the officer exceeded that consent by searching his socks. State v. Ferrell, 2018 Ohio App. LEXIS 18 (11th Dist. Jan. 3, 2018).
Defendant was arrested for assault and battery on a police officer, and a valid search incident of his person produced a hotel room key. Finding the key resulted in an admission that linked defendant to a sex trafficking investigation. The statement he made after the finding of the key was erroneously suppressed by the trial court. Commonwealth v. Barbosa, 2018 Mass. App. LEXIS 1 (Jan. 3, 2018).*