With a dog alert on a car, the search of a locked toolbox under the automobile exception was permissible. State v. Sullivan, 2019-Ohio-2279, 2019 Ohio App. LEXIS 2372 (12th Dist. June 10, 2019).
Exigent circumstances could not be used to justify a warrantless entry to look for a person allegedly inside wanted on an arrest warrant. Too much time had passed between when he’d been previously believed to be there and the entry. The government’s reliance on Strieff is also rejected because Strieff was present at the time. United States v. Hunter, 2019 U.S. Dist. LEXIS 95517 (N.D. Cal. May 31, 2019).*
Defendant in his 2255 admitted that he consented to a search, but he suggests without an offer of proof that it was involuntary, and this isn’t pleading enough. Aceves v. United States, 2019 U.S. Dist. LEXIS 95488 (S.D. Cal. June 6, 2019).*