Defendant’s open consent to search a vehicle included the spare tire compartment because it’s known that people secrete things there. United States v. Stevens, 2019 U.S. Dist. LEXIS 191954 (W.D. Ky. Sept. 29, 2019), adopted, 2019 U.S. Dist. LEXIS 190842 (W.D. Ky. Nov. 4, 2019).
The affidavit for this search warrant does not adequately describe why the police need a search warrant and what it is for: an investigation into child abuse and neglect, drugs, or firearms and why they are illegally possessed. Nevertheless, after a lengthy discourse on the four Leon factors, the court finds the good faith exception applies. United States v. Maynes, 2019 U.S. Dist. LEXIS 191502 (D.N.M. Nov. 5, 2019).*
In an immigration appeal, failure to argue an egregious Fourth Amendment violation in the opening brief was waiver. Hernandez-Romero v. Barr, 2019 U.S. App. LEXIS 33069 (9th Cir. Nov. 5, 2019).*