Officer’s leaning into the open window of defendant’s car with a flashlight to get a better view was not a plain view. Statute “commands police officers, upon detaining a citizen in connection with the investigation or commission of any offense, to fully advise the detained citizen of the reason for the detention. It is a corollary that a citizen has the right to ask for a full explanation of why he is being detained. As a matter of law, the officers’ characterizations of Robinson’s requests for this explanation cannot serve as a basis for reasonable suspicion. The same is true of Robinson’s refusal to consent to a search of his truck, and his objection to Officer Hackett’s unconstitutional search of the truck.” There was no reasonable suspicion for a protective search of defendant’s vehicle, either. State v. Robinson, 2020 La. App. LEXIS 473 (La. App. 2 Cir. Mar. 18, 2020).
The person in defendant’s room caring for his child had apparent authority to consent to the search. She was the primary tenant of the property and had control over all of it. United States v. Howard, 2020 U.S. App. LEXIS 8505 (6th Cir. Mar. 16, 2020).*