CA6: OUI arrest justified search incident for visible beer cans

Defendant’s OUI arrest justified a search incident of the car for beer cans that were visible to the officer. United States v. Latham, 2019 U.S. App. LEXIS 4188 (6th Cir. Feb. 12, 2019).

Defendant’s motion for new trial incorporates his search claim, but asserts no new grounds. United States v. Wagner, 2019 U.S. Dist. LEXIS 22171 (D. Kan. Feb. 12, 2019).*

Defense counsel wasn’t ineffective for not pursuing alleged evidence about a search that the defense did receive in discovery. Pena v. United States, 2019 U.S. Dist. LEXIS 23628 (S.D. N.Y. Feb. 12, 2019).*

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