W.D.Pa.: Court doesn’t find running away from a wrecked car was unequivocally an abandonment

Defendant was an accused bootlegger who knew he was being tailed and he wrecked his car and ran away. The court doesn’t find this to be unequivocally an abandonment because he knew he was being followed but not necessarily by the police. The court on its own raises inevitable discovery and finds that the defendant had an opportunity to make enough of a record on it. The court finds it valid as an inventory. United States v. Brooks, 2018 U.S. Dist. LEXIS 210921 (W.D. Pa. Dec. 14, 2018).*

“We thus conclude, applying Jimenez and Miller, that the officer’s question was reasonably related to a lawful criminal investigation and, therefore, did not unlawfully extend the stop. In so holding, we are especially mindful, as was the Supreme Court in Miller, that the ‘reasonable relationship’ test ‘“is not a demanding one.”’” State v. Toll, 295 Ore. App. 277, 2018 Ore. App. LEXIS 1574 (Dec. 14, 2018).*

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