The search warrant for a hotel room authorized seizure of the key to the hotel room to gain access when the officers came upon it. Plain view applied. Even if plain view didn’t apply, the only suppression would be the key itself, and not the search of the room. The search warrant was issued on probable cause. United States v. Joyner, 2019 U.S. Dist. LEXIS 67996 (D. Conn. Apr. 23, 2019).
A search claim adjudicated in the direct appeal can’t be relitigated in a post conviction proceeding. State v. Restrepo-Duque, 2019 Del. Super. LEXIS 205 (Apr. 24, 2019).*
The probation search was not shown to be a subterfuge for a criminal investigative search, and it was valid. State v. Spriggs, 2019 La. App. LEXIS 720 (La. App. 5 Cir. Apr. 24, 2019).