Officers had a search warrant for defendant’s car, but he also had a community corrections search waiver on file. (The latter wasn’t even acknowledged by the parties.) Defendant was suspected of an ongoing operation of drug selling, so the older information in the affidavit wasn’t stale. Defendant also argues that admission of the search warrant affidavit into evidence was error as hearsay. Based on all the evidence in the record, it’s harmless at best. In addition, the record isn’t clear that the jury ever saw it: all other exhibits say that they were published to the jury, but this one wasn’t. Bailey v. State, 2019 Ind. App. LEXIS 367 (Aug. 16, 2019).
Police responding to a disturbance at a trailer park encountered a woman. While talking to her, defendant walked up. The officer shined his flashlight to see defendant’s face, but lowered it when requested. Defendant was seen standing on a bag of methamphetamine. He was arrested for that, and his encounter was not an investigative stop. United States v. Turner, 2019 U.S. App. LEXIS 24491 (8th Cir. Aug. 16, 2019).*