NC: Expired registration stop does not support SI under Gant

Arrest for expired registration and lack of insurance cannot justify a search incident of the car’s interior under Gant, in a case GVRed after Gant (reversing prior holding). State v. Carter, 200 N.C. App. 47, 682 S.E.2d 416 (2009), on remand from Carter v. North Carolina, 129 S. Ct. 2158, 173 L. Ed. 2d 1153 (U.S., 2009).

Officer’s prior knowledge of the defendant’s heavy meth involvement was RS for a patdown when defendant was stopped. Boyd v. State, 300 Ga. App. 455, 685 S.E.2d 319 (2009).*

Defendant had automatic standing under state law where it was alleged he was guilty of possession in the place searched. Commonwealth v. Ware, 75 Mass. App. Ct. 220, 913 N.E.2d 869 (2009).*

Officers doing a criminal history check during a traffic stop does not make the stop unreasonable. State v. Reed, 2009 Tenn. Crim. App. LEXIS 775 (September 17, 2009).*

Trial court found that defendant’s stop was not justified because of a seat belt violation, and the officer was simply found not credible. The evidence does not preponderate against that finding. State v. Walker, 2009 Tenn. Crim. App. LEXIS 780 (September 21, 2009).*

Knock-and-talk approach veered off and officers instead went to defendant’s outbuilding, and the search was unreasonable. Defendant’s later consent was not sufficiently attenuated from the unlawful search. State v. Greene, 2009 Tenn. Crim. App. LEXIS 777 (September 22, 2009).*