Defendants’ challenges to the state issuing magistrate’s jurisdiction over geolocation information that crosses jurisdictional lines were based on a Franks challenge that was negligence at worst and not an intentional misrepresentation as to the judge’s jurisdiction. Besides, as interesting as the arguments are, they only show that the state actors all acted with good faith. United States v. Rauda-Constantino, 2020 U.S. Dist. LEXIS 14915 (N.D.Ga. Jan. 28, 2020).
A police sergeant was walking in a bar’s parking lot. The place was known for a lot of illegal activity (fights, drugs, guns, liquor violations). He smelled burning marijuana and followed the smell to defendant’s car where he saw a burned joint and marijuana in plain view. The encounter was reasonable. State v. Crawford, 2020-Ohio-268, 2020 Ohio App. LEXIS 234 (8th Dist. Jan. 30, 2020).*