Defendant was stopped for a traffic offense, and his tinted windows were way too dark and the officer couldn’t see inside. Defendant was told to lower the window, and he did. The officer could immediately see a knotted plastic bag sticking out of defendant’s waistband at above his groin. The officer, by training and experience, immediately suspected it was drugs, and he ordered defendant of the car. And it was. The search was premised on a plain view, and then a search incident of the car was permitted, and a gun was found. United States v. Belton, 2019 U.S. Dist. LEXIS 24995 (D.D.C. Feb. 15, 2019).
Defendant was convicted of RICO murder. The use of CSLI to place him at the scene of the murder in 2009 wasn’t barred by Carpenter decided nine years later. United States v. Herron, 2019 U.S. App. LEXIS 4679 (2d Cir. Feb. 14, 2019).*