During a traffic stop, defendant consented to a search of her car. She was out of the car and her purse was inside. The consent was open-ended, and it thus would include closed containers, like her purse in the front seat of her car. State v. Tepfenhart, 2019-Ohio-4599, 2019 Ohio App. LEXIS 4640 (2d Dist. Nov. 8, 2019).
Defendant was evicted from a motel for allegedly threatening another guest with a gun. When housekeeping was removing all his stuff, she found a gun which was reported to the police. He lacked a reasonable expectation of privacy after eviction, and it was a private search. United States v. Allen, 2019 U.S. Dist. LEXIS 194242 (M.D.Fla. Oct. 7, 2019),* adopted, 2019 U.S. Dist. LEXIS 193469 (M.D.Fla. Nov. 7, 2019).*