MA: “Freezing” house for alleged prostitution for alleged exigency was unreasonable

Police “froze” a house and searched the second floor for evidence of alleged prostitution; couldn’t be justified on this record. What physical evidence would there be? Commonwealth v. Owens, 480 Mass. 1034 (Nov. 7, 2018).

There was a mistake in the affidavit but it wasn’t shown to be any more than negligent, and it wasn’t material to the finding of probable cause. United States v. Gonzalez-Arreola, 2018 U.S. Dist. LEXIS 191435 (N.D. Ga. Sept. 27, 2018).*

A traffic stop plus an open beer can was probable cause. State v. Jackson, 2018 N.C. App. LEXIS 1086 (Nov. 8, 2018).*

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