MS: Def was in open fields when he encountered wildlife officers and admitted he had meth on him

On the opening day of dove hunting season, wildlife officers were out. They heard shooting from open lands and went to investigate. They encountered defendant and another, and defendant tossed a bag aside when officers approached him. They asked what was in the bag, and he said “meth.” It turned out his grandmother owned the land, but it was open fields and was nowhere near the curtilage of her house. He lacked a reasonable expectation of privacy in the field. Tullos v. State, 2019 Miss. App. LEXIS 598 (Dec. 17, 2019).*

“The district court properly dismissed Martin’s action because Martin failed to allege facts sufficient to show that Berg and Rini in fact arrested him.” Martin v. Berg, 2019 U.S. App. LEXIS 37544 (9th Cir. Dec. 18, 2019).*

Defendant’s 2255 claimed defense counsel failed to move to suppress the contents of his cell phone because of lack of a search warrant. Except there was a search warrant. Blanc v. United States, 2019 U.S. Dist. LEXIS 217091 (S.D. Fla. Dec. 17, 2019).*