WY: Detention was reasonably extended as RS developed and defendant consented

Defendant’s motion to suppress drugs seized after a traffic stop because of the scope of the detention was denied, given that the original purpose of the stop was not yet complete when the officer inquired about defendant’s travel plans and rental car agreement. Defendant thus voluntarily consented to further questioning, and during the officer’s conversation with defendant he smelled marijuana, which gave him probable cause to search defendant’s car. Ray v. State, 2018 WY 146, 2018 Wyo. LEXIS 151 (Dec. 31, 2018).*

Trial court’s comment on the ease of getting a search warrant didn’t denigrate defense counsel or deny a fair trial. State v. Swint, 2018-Ohio-5384, 2018 Ohio App. LEXIS 5698 (5th Dist. Dec. 21, 2018).*

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