The police were in defendant’s house and observed guns. They didn’t realize that he was a felon in possession until two weeks later. Then they sought a warrant 23 days after seeing the guns. That wasn’t unreasonable considering the fact that guns are kept “and are of continuing utility to the owner.” (This arose in the context of an IAC claim. Since defendant would have lost on the merits, there’s no IAC.) State v. Ash, 2018-Ohio-1139, 2018 Ohio App. LEXIS 1226 (7th Dist. Mar. 15, 2018).
The totality here supported exigent circumstances warrantless taking of defendant’s blood. State v. Zalcberg, 2018 N.J. LEXIS 354 (Mar. 27, 2018).*