The Fourth Amendment decision that the search was reasonable and lawful in defendant’s criminal case is collateral estoppel to a civil claim over the search. Harvey v. United States, 2018 U.S. Dist. LEXIS 5282 (S.D. Fla. Jan. 9, 2018).
The trial court made insufficient findings of fact and conclusions of law on whether there was a valid plain view, so the case is remanded to the trial court. State v. Burnham, 289 Ore. App. 783, 2018 Ore. App. LEXIS 93 (Jan. 11, 2018), reconsidering and withdrawing 287 Ore. App. 661, 403 P.3d 466 (2017).*