Defendant was arrested on suspicion of murder, and he had a cell phone in his pocket that he was using, his younger brother’s. The seizure of the phone was proper, but the purported inventory of the phone was not because it was for investigative purposes and exceeded any justifiable reason to search it. Commonwealth v. Barillas, 484 Mass. 250 (Mar. 6, 2020).
There was probable cause that defendant was involved in a drug deal from his car. That was enough to detain him and search the car. United States v. Walker, 2020 U.S. Dist. LEXIS 38650 (E.D. Mo. Jan. 6, 2020), adopted, 2020 U.S. Dist. LEXIS 36331 (E.D. Mo. Mar. 3, 2020).*