W.D.Mo.: Video of contents of car satisfied inventory

Defendant argues the inventory was really investigatory. He doesn’t claim anything was missing or lost. He also was on someone else’s property at 5 am, so there was no need to leave it there because the owner couldn’t assent, assuming he would. The officers videoed the inventory rather than make a list. There was nothing wrong with the inventory. Alternatively, the search of the car was valid because of the smell of marijuana. United States v. Goldman, 2020 U.S. Dist. LEXIS 47589 (W.D. Mo. Feb. 4, 2020), adopted, 2020 U.S. Dist. LEXIS 46784 (W.D. Mo. Mar. 18, 2020).

The first stop was invalid because the officer failed to remember anything about the stop when he testified, and the video doesn’t show the violation. The second stop, however, had a factual basis, and the smell of marijuana supported the search. State v. Lask, 2020-Ohio-1037, 2020 Ohio App. LEXIS 966 (4th Dist. Mar. 6, 2020).*

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