A priority mail box was partially open and inadequately sealed in a post office on tribal lands. A baggie of apparent methamphetamine was visible inside. The post office called the tribal police, and that officer saw it too. This was within the plain view exception even though the box was partially closed. United States v. Emery, 2019 U.S. Dist. LEXIS 104812 (D.S.D. June 24, 2019).
Habeas petitioner couldn’t make a Fourth Amendment claim on habeas. His Sixth Amendment claim for not pursuing the Fourth Amendment was waived by his guilty plea. Warner v. Ryan, 2019 U.S. Dist. LEXIS 105129 (D. Ariz. June 24, 2019).*