Defendant’s cell phone was seized from his car when it was impounded after a high speed chase. The fact it was omitted from the inventory sheet does not make its seizure unreasonable. It was ultimately searched with a search warrant. United States v. Garay, 2019 U.S. App. LEXIS 27908 (9th Cir. Sept. 17, 2019).
The district court suppressed defendant’s stop and frisk outside and next door to a house being searched under a warrant. On the totality of circumstances, however, the officers had reasonable suspicion as to him based on observations earlier in the evening. Reversed. United States v. McElrath, 2019 U.S. App. LEXIS 27905 (6th Cir. Sept. 17, 2019).*