The officer unreasonably extended the stop past the time for resolving the alleged traffic violations. He told defendant to get into the police car, and defendant did, but left the passenger door open with his right leg out. The officer ordered him to shut the door or else. That was a seizure in itself that told defendant he wasn’t free to leave. State v. Reed, 2020 N.C. LEXIS 103 (Feb. 28, 2020).
In a child porn warrant application, there was no Franks violation for describing the images as “lifelike” when referring to toys. (It’s complicated; you don’t need more. This also didn’t need to be published.) United States v. Larson, 2020 U.S. App. LEXIS 6215 (1st Cir. Feb. 28, 2020).*