Driving on a suspended license is an offense for which (1) search incident is valid, and (2) the driver can’t continue and the vehicle would be impounded and subject to a proper inventory. In this case, the inventory was not pretextual, and it “morphed” into probable cause for the automobile exception. Commonwealth v. Rosario-Santiago, 96 Mass. App. Ct. 166 (Oct. 2, 2019).
One issue on appeal was CSLI gathered in violation of Carpenter which was after his conviction and the issue was never raised below. It’s waived. Terrell v. State, 2019 Ark. App. LEXIS 466 (Oct. 2, 2019).*