Just because defendant’s girlfriend rented a motel room and he was with her doesn’t make the motel parking lot their curtilage. “[N]ot even a hotel’s owner, to say nothing of its transitory guests, has a reasonable expectation of privacy in its open parking lot.” The officer approached a car with what he at first thought was a passed out driver and then smelled burning marijuana. United States v. Jasper, 2020 U.S. Dist. LEXIS 66381 (S.D. Ga. Mar. 2, 2020), adopted, 2020 U.S. Dist. LEXIS 64778 (S.D. Ga. Apr. 11, 2020).
The exigency inherent in the automobile exception continues after the defendant’s arrest. State v. Domenig, 2020 Iowa App. LEXIS 399 (Apr. 15, 2020).
Defendant’s swerving that the officer claimed was the reason for the stop was caused by the quickly approaching police car, and that precludes finding reasonable suspicion for the stop. State v. Wadden, 2020 Iowa App. LEXIS 407 (Apr. 15, 2020).