Defendant’s longtime girlfriend looked in his briefcase for information about a prior housekeeper, and she looked at a flash drive and scrolled through folders. She stumbled upon a photograph of her daughter sleeping shirtless. She turned the drive over to the police. They looked at the drive trying to find the original picture and saw others. The trial court held that this didn’t exceed the original search, but the case is remanded for more findings of fact and conclusions of law to better explain why the officer did not exceed the private search. State v. Terrell, 2018 N.C. App. LEXIS 102 (Feb. 6, 2018).
After a traffic stop, officers developed reasonable suspicion from conversations with the occupants, and he asked for and obtained voluntary consent separately from both occupants. United States v. Corrujedo, 2018 U.S. Dist. LEXIS 19102 (E.D. Tex. Feb. 6, 2018),* R&R 2017 U.S. Dist. LEXIS 217032 (E.D. Tex. Dec. 22, 2017).*