WA: A purse and a closed pouch within are subject to search incident

Defendant was subject to a valid search incident, and that included not only her purse, but also a pouch within her purse. State v. Richards, 2019 Wash. App. LEXIS 2772 (Oct. 29, 2019).

Officers saw defendant and others and ordered them to put their hands up. Two men did, but defendant didn’t and he started to turn a way. He wasn’t seized with the order since he refused to comply. He was instead seized when the officers grabbed him. People v. McMichaels, 2019 IL App (1st) 163053, 2019 Ill. App. LEXIS 861 (Oct. 29, 2019).

A crooked license plate justified defendant’s traffic stop because it was partially obscured. United States v. Sims, 2019 U.S. Dist. LEXIS 187313 (D. Kan. Oct. 28, 2019).*

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