LA1: Parolee’s positive drug screen justified home search

Defendant’s positive drug screens were reason for an unannounced home and cell phone text message parole search. State v. St. Cyre, 2019 La. App. LEXIS 2305 (La. App. 1 Cir. Dec. 19, 2019).

An officer found two people asleep in a car with the engine running, and he did a welfare check. Telling them to turn off the engine and open the window and door was reasonable, and then the burnt marijuana was apparent. State v. Brumelow, 2019 Fla. App. LEXIS 18931 (Fla. 1st DCA Dec. 20, 2019).*