MA: Obtaining and executing arrest warrant in middle of night for a rash of burglaries was reasonable

Police were investigating a rash of burglaries, and woke up a magistrate in the middle of the night to get an arrest warrant for defendant. Officers went to arrest him and others were seeking a search warrant. At his apartment, they found proceeds from the burglaries. The independent source doctrine was satisfied [as would be inevitable discovery because they sure had enough to get the search warrant and did]. Commonwealth v. Pearson, 2019 Mass. App. LEXIS 141 (Oct. 28, 2019).*

After a traffic stop, the officer developed reasonable suspicion for a field sobriety test. State v. Williams, 2019-Ohio-4414, 2019 Ohio App. LEXIS 4478 (5th Dist. Oct. 24, 2019).*

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