N.D.Ala.: Protective sweep of nearby shed on def’s arrest in wooded area valid

Defendant was arrested in an open wooded area, and the protective sweep of a shed near him was valid. United States v. Flanagan, 2019 U.S. Dist. LEXIS 100047 (N.D. Ala. May 29, 2019), adopted, 2019 U.S. Dist. LEXIS 99228 (N.D. Ala. June 13, 2019).

If there is probable cause, “the ‘automobile exception’ has no separate exigency requirement” under Maryland v. Dyson. United States v. Solis, 2019 U.S. Dist. LEXIS 99952 (D. Kan. June 14, 2019).*

CSLI obtained six months before Carpenter is subject to the good faith exception. United States v. Cooper, 2019 U.S. Dist. LEXIS 98929 (N.D. Ga. June 13, 2019).*

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