CA4: Def’s admission she had cocaine in her hair permitted search incident of her car where arrested

“After finding a bag of white powder in Harrison’s hair — which she admitted to the arresting officer was cocaine — and observing a suspicious baggie and a large amount of cash in plain view, the officers had a ‘reasonable basis’ to believe they might find additional drugs in the Camry in which Harrison, an arrestee, was a passenger.” Thus, the search incident exception applies. United States v. Norman, 2019 U.S. App. LEXIS 24312 (4th Cir. Aug. 15, 2019).

The court does not need to decide whether defendant’s supervised release search condition authorized this search because it was justified under the automobile exception based on the officer’s observations of defendant. United States v. McCoy, 2019 U.S. Dist. LEXIS 137657 (N.D. Cal. Aug. 14, 2019).*

The joint motions to suppress are denied as untimely and slowing the progression of this case. United States v. FÍgaro-BenjamÍn, 2019 U.S. Dist. LEXIS 139277 (D. P.R. Aug. 16, 2019).*