Activating a key fob to find the car it belongs to is not a search. “Moreover, the Sixth Circuit has held that ‘[t]he mere insertion of a key into a lock, by an officer who lawfully possesses the key and is in a location where he has a right to be, to determine whether the key operates the lock, is not a search.’ United States v. Salgado, 250 F.3d 438, 456 (6th Cir. 2001). Therefore, Supervisor Stine’s activation of the lock and unlock features on the key fob, which were lawfully in his possession, was not a search of the SUV and did not violate the Fourth Amendment.” United States v. Gaither, 2018 U.S. Dist. LEXIS 28582 (E.D. Ky. Feb. 22, 2018).
Driving an Enterprise rental car with a removed bar code, six air fresheners, and nervousness was reasonable suspicion. United States v. Lewis, 2018 U.S. App. LEXIS 4538 (2d Cir. Feb. 23, 2018).*