Defendant crossed into the U.S. at a pedestrian border crossing. A dog sniff of the person was conducted. “The Court finds that the intrusiveness of the canine search did not rise to the level of a non-routine search, which would require reasonable suspicion. Further, the Court believes Kelly is particularly instructive and finds that the canine search is less intrusive than a pat-down search and requires no individualized suspicion at the international border.” United States v. Javalera-Hernandez, 2019 U.S. Dist. LEXIS 1053 (D. Ariz. Jan. 3, 2019).
Automobile exception search justified by officer smelling marijuana and defendant’s admission there was 4-5 pounds in the car. United States v. Valdes, 2019 U.S. Dist. LEXIS 796 (D. Me. Jan. 3, 2019).*