N.D.Ohio & S.D.Miss.: SW including “any vehicle on the premises” is still particular

A search warrant that authorized the search of “any vehicle on the premises” was not unparticular because it allowed searches of visitor’s cars too. Plenty of cases already hold that “any vehicle on the premises” is particular. Moreover, there was probable cause as to the vehicle and the automobile exception would permit searches of them. United States v. Shephard, 2019 U.S. Dist. LEXIS 184161 (N.D. Ohio Oct. 24, 2019). Accord: United States v. Ward, 2019 U.S. Dist. LEXIS 186086 (S.D. Miss. Oct. 28, 2019).

The officer watching what appeared to be a hand-to-hand transaction had at least reasonable suspicion for a stop. State v. Smith, 2019-Ohio-4373, 2019 Ohio App. LEXIS 4440 (2d Dist. Oct. 25, 2019).*

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