Defendant was driving a car that belonged to his passenger, and it was legitimately stopped because of an expired tag. The court gave a long exposé of property rights and standing useful in the future, but not for him because the court ultimately concludes he has no standing in the car. The officer concluded defendant was driving under the influence of drugs and called for a drug dog. The search also would have been valid as an inventory, but not as a search incident as the trial court found. Bolin v. Commonwealth, 2019 Ky. App. LEXIS 198 (Nov. 9, 2019).
Officers had authority to search the files on defendant’s electronic devices for photographic evidence of drug crimes, and that led to a valid plain view of child pornography. Commonwealth v. Stanley, 2019 Va. App. LEXIS 260 (Nov. 12, 2019).*