Pinging a cell phone to find its location was a search under the Massachusetts Constitution and Fourth Amendment, but it was reasonable because the state showed true exigent circumstances. Commonwealth v. Almonor, 482 Mass. 35 (Apr. 23, 2019).
Washington declines to adopt a per se rule that “We need not decide if Washington should adopt a per se rule that the obstructing of the accused’s exit in a car always constitutes a seizure. Other factors, along with the officer’s blocking the Monte Carlo’s passageway, contribute to our conclusion.” State v. Carriero, 2019 Wash. App. LEXIS 978 (Apr. 25, 2019).*