CSLI was admitted involving defendant’s girlfriend’s cell phone that defendant was using. He made no effort to show standing in the cell phone. Defense counsel wasn’t ineffective for not raising standing. Albright v. State, 2020 Ga. App. LEXIS 187 (Mar. 13, 2020).
While smell of alcohol isn’t reasonable suspicion in itself, there was more. “In this case, we similarly find that Officer Meinzer’s extension of the traffic stop for purposes of conducting a DUI investigation was justified by the totality of the circumstances: (1) his observation of a traffic infraction, (2) the odor of alcohol coming from Strickert’s person, (3) Strickert’s watery and bloodshot eyes, and (4) Strickert’s admission to consuming alcohol.” Strickert v. Kan. Dep’t of Revenue, 2020 Kan. App. LEXIS 19 (Mar. 13, 2020).*