A medical marijuana provider told police that it appeared that defendant was reselling that which she acquired legally. They messaged her through Facebook as a potential buyer, and she essentially admitted it. The search warrant was issued on probable cause and the Facebook posts could come into evidence. The proof was overwhelming at trial. Andreavich v. State, 2018 Del. LEXIS 285 (June 20, 2018).
The use of a flashlight to look in defendant’s car at night wasn’t a search, and it could enable a plain view. People v. Woodley, 2018 V.I. LEXIS 61 (June 20, 2018).