Where there was probable cause and the automobile exception applied, the fact defendant walked away from the vehicle didn’t prohibit its search. Cleveland v. State, 2019 Ind. App. LEXIS 316 (July 15, 2019).
Defendant was apparently asleep parked in an alley, and parking in an alley was a traffic violation. When the officer tried to rouse him, he could see drug paraphernalia on the console, and that justified a search. United States v. Musquiz, 2019 U.S. Dist. LEXIS 118238 (D. Neb. July 16, 2019).*