When defendant got out of the car during the stop, the officer ordered him to put down his cell phone and wallet that were in his hands, and he put them on the roof. Inside the car, the officer saw a syringe and a stack of credit cards, and he was suspecting credit card fraud. Probable cause was found for an automobile exception search of the car, and defendant’s wallet on the roof was subject to it. State v. Alls, 2018-Ohio-3353, 2018 Ohio App. LEXIS 3627 (5th Dist. Aug. 22, 2018).
Defendant’s car was sufficiently readily mobile that the automobile exception applies. He does not argue that probable cause is lacking. United States v. Thompson, 2018 U.S. Dist. LEXIS 142379 (D. Nev. Aug. 22, 2018).*
Defendant stated enough to get a suppression hearing, but the issue to be addressed will be inevitable discovery. United States v. Okparaeke, 2018 U.S. Dist. LEXIS 142515 (S.D. N.Y. Aug. 22, 2018).*