It was reasonable to open a car door to read the VIN on the doorjamb under New York v. Class because the officer couldn’t see the one on the dashboard because of the glare of the sun. Otherwise, there was no probable cause for opening the door. United States v. Alderete, 2020 U.S. Dist. LEXIS 80711 (D. N.M. May 7, 2020).
When the USMJ makes three findings on the legality of a search, and defendant objects to only one, the other two are waived, and, here, they support the search. United States v. Gibson, 2020 U.S. App. LEXIS 14592 (7th Cir. May 7, 2020).
The state showed nexus to defendant’s phone and the aggravated assault under investigation. Defendant was alleged to have shown a Snapchat post news story on the phone when admitting to another about being involved in the assault. In re X.M., 2020 Tex. App. LEXIS 3884 (Tex. App. – Amarillo May 6, 2020).