There was probable cause by a plain view so the automobile exception applies. The fact defendant as in custody doesn’t require a search warrant. United States v. Lightsey, 2019 U.S. Dist. LEXIS 121669 (M.D. Fla. July 3, 2019).
There was an “eminently reasonable” inference that defendants were engaged in serial shoplifting from a Walmart. After leaving and going to their truck, they went back into the store. There was probable cause. United States v. Vance, 2019 U.S. Dist. LEXIS 121702 (E.D. Tenn. July 1, 2019),* adopted, 2019 U.S. Dist. LEXIS 120697 (E.D. Tenn. July 19, 2019).*
The trial court erred in suppressing jail telephone calls obtained by grand jury subpoena. State v. Jackson, 2019 N.J. Super. LEXIS 116 (July 19, 2019).*