D.Nev.: Def was handcuffed and in police car, so search incident didn’t apply; it was inevitable, however, inventory would happen

Defendant’s arrest led to a search incident of luggage, but he was handcuffed and in a police car. So, the search incident doctrine can’t apply, but an inventory would have inevitably occurred, so that provides an independent basis for the search. United States v. Brown, 2018 U.S. Dist. LEXIS 6412 (D. Nev. Jan. 16, 2018).

After miscarriages, samples were taken from plaintiff for purposes of chromosomal testing. When she and her husband later sued the Ob-Gyn clinic for an IUD that allegedly caused the miscarriages, the taking and testing of the samples was a private search and involved no constitutional invasion. Carr v. Ferrell-Duncan Obgyn Clinic, 2018 Mo. App. LEXIS 40 (Jan. 16, 2018) (sounds like an argument brought by a tort lawyer).

Defendants weren’t stopped by the police: they were parked when the police approached to talk to them. The officers had observed a likely drug deal going down, and they had reasonable suspicion when defendants were frisked. The trial court erred in finding the stop became unreasonable. People v. Fields, 2018 CO 2, 2018 Colo. LEXIS 17 (Jan 16, 2018).*