Defendant didn’t raise the constitutionality of satellite-based monitoring in the trial court, so it’s waived for appeal. He also can’t bring it up by certiorari. State v. DeJesus, 2019 N.C. App. LEXIS 384 (May 7, 2019).
Reasonable suspicion developed at the scene when the officer was confronted with the overwhelming odor of air freshener emanating from defendant’s car which, coupled with the officer’s observations, taking into account his training and experience, suggested criminal activity. State v. Nelson, 2019 N.J. LEXIS 598 (May 8, 2019).*
The inventory search of defendant’s car was lawful, and his § 1983 Fourth Amendment claim is rejected. Crockett v. City of Gresham, 2019 U.S. Dist. LEXIS 76730 (D. Ore. May 7, 2019).*