Failure to get a ruling on a search claim in the trial court is waiver of the issue for appeal. People v. Collins, 2020 NY Slip Op 04517, 2020 N.Y. App. Div. LEXIS 4610 (1st Dept. Aug. 13, 2020).
Drug dog’s unexpected jumping into defendant’s car wasn’t a search. The dog had already alerted. The officer had reasonable suspicion from defendant’s contradictory and suspicious explanation of his travels which was contrary to his first explanation. State v. Randall, 2020 Ida. App. LEXIS 62 (Aug. 13, 2020).
Older trash pull wasn’t stale when combined with another three days before search warrant issued. United States v. Threalkill, 2020 U.S. Dist. LEXIS 145259 (M.D. Tenn. Aug. 13, 2020).*