FL2: Def gets benefit of Byrd where issue raised before it was decided; remanded

Defendant was not listed as an authorized driver of a rental car, and he moved to suppress the search of the rental car. Because his case was in “the pipeline,” he gets the benefit of Byrd and the case is remanded for a new suppression hearing. Jeansimon v. State, 2019 Fla. App. LEXIS 11973 (Fla. 2d DCA July 31, 2019).

The CI’s information was specific and substantially corroborated. Nexus to the premises was also shown. United States v. Calhoun, 2019 U.S. Dist. LEXIS 124367 (E.D. Mich. July 25, 2019).*

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