Defendant at first consented to the government holding and then searching his cell phone and laptop. The next day he revoked his consent on the computer. The government continued to hold the laptop to preserve evidence and got a search warrant for it within six hours. This was reasonable. United States v. Ramsey, 2020 U.S. Dist. LEXIS 80153 (E.D. Pa. May 4, 2020).
Gant justified the search of defendant’s car for drugs. He was arrested for drugs, then a dog alerted on the car, too. The court discusses Gant and looking for evidence of the “crime of arrest” but only the automobile exception in passing. State v. Fredericks, 2020 Fla. App. LEXIS 4916 (Fla. 4th DCA Apr. 8, 2020) (this seems like a classic automobile exception case anyway).
“Because Farris was not able to move the car himself, Sergeant Mellady was statutorily authorized to remove the vehicle. Because the impoundment was proper, the inventory search was a valid exception to the warrant requirement of the Fourth Amendment.” Farris v. State, 2020 Ind. App. LEXIS 144 (Apr. 8, 2020).