State case law already permits officers to detain bystanders for a reasonable period for officer safety in execution of search warrants. The court adopts the Sixth Circuit rule and extends it to arrest warrants, too. “We hold that detaining Constant in the apartment for the purpose of streamlining B.P.’s arrest was valid and in keeping with federal precedent. Summers, 452 U.S. at 697-98 …” Constant v. Commonwealth, 2020 Ky. App. LEXIS 47 (Apr. 24, 2020).
The search warrant that found a video in defendant’s text messages was valid despite the search warrant not specifically mentioning cell phones in the body but in an attachment. United States v. Vetri, 2020 U.S. App. LEXIS 13068 (3d Cir. Apr. 23, 2020).
A cracked windshield didn’t support a dog sniff under Oregon law. State v. Sherriff, 303 Ore. App. 638, 2020 Ore. App. LEXIS 541 (Apr. 22, 2020).