A deputy sheriff was doing off-duty security work at a hospital same day surgery parking lot when he saw the defendant slumped over his steering wheel, the door open, and the engine off. When the officer turned on his take down lights, defendant came to and abruptly got out of the car and walked toward the officer who ordered him back to his car. Defendant’s detention was reasonable under the emergency aid exception. The fact defendant abruptly came to wasn’t determinative. Randall v. State, 2018 Ind. App. LEXIS 150 (Apr. 26, 2018).
Another Playpen search warrant sustained. United States v. Palaniappan, 2018 U.S. Dist. LEXIS 71289 (E.D. N.Y. Apr. 28, 2018).*