A pill bottle on top of a dresser wasn’t subject to plain view because its incriminating nature wasn’t immediately apparent. United States v. Crawford, 2020 U.S. Dist. LEXIS 74440 (E.D. Tenn. Apr. 6, 2020), adopted, 2020 U.S. Dist. LEXIS 73477 (E.D. Tenn. Apr. 27, 2020).
An officer tapping on defendant’s car window to get his attention was not a seizure when the defendant didn’t intend to leave anyway. United States v. Baker, 2020 U.S. Dist. LEXIS 75257 (M.D. Ala. Mar. 16, 2020), adopted, 2020 U.S. Dist. LEXIS 74314 (M.D. Ala. Apr. 28, 2020).
Officers boxing in defendant’s car was not a seizure of his person when he abandoned the vehicle and fled. Thus, there was abandonment of the car and the waiver of any reasonable expectation of privacy in it. Also, because the car had stolen plates, it would have been inventoried anyway; thus, a seizure was inevitable. United States v. Johnson, 2020 U.S. App. LEXIS 13587 (11th Cir. Apr. 28, 2020).