Under 404(b), the officers will be permitted to testify at trial to controlled buys that led to the search warrant. United States v. Martinez, 2019 U.S. Dist. LEXIS 154066 (D. N.M. Sept. 10, 2019).
Defendants were stopped for speeding, and the officer approached from the passenger side and could smell marijuana in the car. He also saw a pine tree air freshener folded and stuck in the air vent, which was unusual. Then the stories of the two weren’t the same. There was then reasonable suspicion for a dog sniff. United States v. Yard, 2019 U.S. Dist. LEXIS 154326 (W.D. N.Y. May 14, 2019),* adopted, 2019 U.S. Dist. LEXIS 154157 (W.D. N.Y. Sept. 10, 2019).*
There was probable cause for a DNA sample, and the affidavit was not bare bones. It was substantial enough that the good faith exception had to apply and it would be egregious not to. United States v. Williams, 2019 U.S. Dist. LEXIS 154125 (M.D. Tenn. Sept. 10, 2019).*