N.D.Iowa: Govt overcame presumptively unreasonable search finding a bullet hole to validate SW for premises

Defendant showed that filing his motion to suppress nearly a year late under the motions deadline was with good cause because of continuances of the trial and changes in counsel. A bullet hole in a hallway wall was discovered by a presumptively unreasonable warrantless search, but the government shows that the good faith exception should apply. The finding of the bullet hole led to issuance of a search warrant. United States v. Martinez-Rubio, 2019 U.S. Dist. LEXIS 206213 (N.D. Iowa Nov. 27, 2019).*

Plaintiff’s arrest for using an 18-wheeler’s air horn on a passenger vehicle in a school zone was justified with probable cause. Alvarez-Mena v. Miami-Dade Cty. 2019 Fla. App. LEXIS 17900 (Fla. 3d DCA Nov. 27, 2019).*

Defendant’s presence on the premises when the search warrant was executed helped the state establish constructive possession of the drugs. State v. Floyd, 2019-Ohio-4878, 2019 Ohio App. LEXIS 4955 (7th Dist. Nov. 1, 2019).*

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