OR: Officer had subjective PC, but it wasn’t objectively reasonable on totality; suspicious, yes, PC, no

The officer subjectively had probable cause to believe defendant was in possession of drugs, but it was not objectively reasonable on the totality. “Applying those standards here, we conclude that, even when viewed through the lens of Haugen’s training and experience, the totality of the circumstances—including defendant’s connection to Mauel, the items found in Mauel’s truck, defendant’s appearance, and her apparent use of a false name—did not objectively establish a reasonable basis to believe that, more likely than not, defendant possessed methamphetamine, constructively or otherwise. As a result, the officer who arrested defendant and searched her incident to that arrest lacked probable cause to do so. The trial court, therefore, erred in denying defendant’s motion to suppress.” State v. Sanchez-Anderson, 300 Or. App. 767, 2019 Ore. App. LEXIS 1563 (Nov. 27, 2019) (under submission 23 months).

Plaintiffs sued over the City of Seattle’s use of regulations to remove encampments, campsites, and personal property left on city property. This was not a facial challenge under the Fourth and Fourteenth Amendments, and class certification is denied for lack of commonality. Willis v. City of Seattle, 2019 U.S. App. LEXIS 35707 (9th Cir. Nov. 29, 2019).*