OH9: Dog sniff of a car in motel parking lot not a search

A dog sniff of a car on a motel parking lot was reasonable and didn’t require reasonable suspicion because there was no stop. State v. Bryner, 2018-Ohio-3215, 2018 Ohio App. LEXIS 3473 (9th Dist. Aug. 13, 2018).

Police had a tracking order on somebody else’s cell phone that ended up in defendant’s car with that person, and it ended up tracking defendant’s car, and this was not unreasonable under the Fourth Amendment. United States v. Peters, 2018 U.S. Dist. LEXIS 135794 (D. Vt. Aug. 13, 2018).

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