Standing for Fourth Amendment purposes is not jurisdictional, so the court can consider the merits instead. United States v. Spadafore, 2020 U.S. App. LEXIS 2922 (9th Cir. Jan. 28, 2020).
The legality of the search warrant for defendant’s car is moot because it could have been searched by inventory as an independent basis. State v. Brinkley, 2020 Del. Super. LEXIS 47 (Jan. 24, 2020).
“[B]ased on the totality of the circumstances, Palmer’s proximity to the accident, a suspect description matching Palmer’s race, gender and some articles of clothing, the lack of other pedestrians in the area, and his suspicious reaction after noticing Officer Meyer—there was reasonable suspicion to stop Palmer. See Quinn, 812 F.3d at 700. Therefore, it is recommended that Palmer’s Motion to Suppress Evidence and Statements be denied.” United States v. Palmer, 2020 U.S. Dist. LEXIS 16113 (E.D. Mo. Jan. 10, 2020).*