D.N.J.: Presentation of fake driver’s license to get car from impound after alleged unlawful seizure was new crime and attenuated

Defendant’s presentation of a fake driver’s licenses to recover his car would not be suppressed. The argument that it is connected to defendant’s alleged unlawful seizure of the car fails because it was attenuated. United States v. Minaya, 2019 U.S. Dist. LEXIS 64793 (D.N.J. Apr. 16, 2019).*

In a probation revocation proceeding, a probable cause affidavit containing hearsay was properly authenticated and admissible under state law. Votra v. State, 2019 Ind. App. LEXIS 168 (Apr. 16, 2019).*

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