Even if the officer presumed defendant was in legal possession of cannabis pursuant to Illinois MMJ Act, the facts established probable cause that evidence of a crime was in the vehicle. The officer saw a loose “bud” in the backseat and smelled a strong odor of cannabis which, together, indicated that cannabis was in the car and likely not in its proper container. People v. Hill, 2020 IL 124595, 2020 Ill. LEXIS 182 (Mar. 19, 2020).
There was a factual basis for stopping defendant for not using a headlight on his bicycle at night. The court does not find, however, defendant fled, so any search incident of his person for alleged flight is suppressed because it was not a valid search incident. United States v. Davis, 2020 U.S. Dist. LEXIS 47281 (S.D. W.Va. Mar. 19, 2020).*
Playpen warrant sustained. United States v. Palaniappan, 2020 U.S. App. LEXIS 8691 (2d Cir. Mar. 17, 2020).*