The automobile exception applied to an already parked car because it’s still “mobile” for exigency purposes. United States v. Mizell, 2019 U.S. Dist. LEXIS 138171 (N.D. Ga. July 29, 2019), adopted, 2019 U.S. Dist. LEXIS 137988 (N.D. Ga. Aug. 15, 2019).
Defendant’s stop was without reasonable suspicion, and the officer admitted the purpose to make an investigative stop as soon as he saw defendant. Motion to suppress stop granted. United States v. Tellis, 2019 U.S. Dist. LEXIS 137924 (D. Nev. Aug. 14, 2019).*
Even if it was not a violation of the vehicle code to not signal turning coming out of a parking lot to the street [probably doubtful, but], any mistake of the officer would be objectively reasonable under Heien. United States v. Mills, 2019 U.S. Dist. LEXIS 137779 (E.D. Mich. Aug. 15, 2019).*