Defendant was a lieutenant in the fire department, and his father was the chief. He was using a city owned laptop. After he was arrested for exposing himself in a Walmart bathroom, dad had the apparent and actual authority to consent to search of the city owned computer as the fire chief. The fact defendant had possession and took it home everyday didn’t answer the ultimate question of actual control over the computer. United States v. England, 2020 U.S. Dist. LEXIS 77986 (E.D. Ky. May 4, 2020).
Officers had probable cause defendant possessed heroin, and searched his shoe incident to arrest, finding a pill. The search incident was unreasonable. State v. Blythe, 2020 Ida. LEXIS 94 (May 4, 2020).