Defendant was stopped in a shopping center parking lot for suspicion of shoplifting a sweatshirt. He consented to a frisk of his person and car, and nothing was found. Another officer arrived, and he was de facto arrested. A search of a McDonald’s sack in the car can’t be justified as a search incident. State v. Ledbetter, 2020 Mo. App. LEXIS 580 (May 5, 2020).
There is no reasonable expectation of privacy against a prison cell search, but the Eighth Amendment provides protection against harassing searches. Here, the justification for plaintiff’s cell searches was his efforts at self-mutilation, and that was justification enough. Coit v. Garman, 2020 U.S. App. LEXIS 14277 (3d Cir. May 5, 2020).
A 2019 DEA administrative subpoena for a cell phone’s subscriber information was reasonable and not a violation of Carpenter. CSLI information was obtained by a state search warrant, and it was reasonable. United States v. Armstrong, 2020 U.S. Dist. LEXIS 68476 D. N.D. Apr. 20, 2020).