CA10: Where wrong standard of review applied below, undisputed facts allow appellate court to still decide

“Because the evidence presented by the government at the evidentiary hearing in this case was largely undisputed, we conclude that the district court’s factual findings were not clearly erroneous, and that its misapplication of the standard of review does not constitute reversible error.” United States v. Madrid-Mendoza, 2020 U.S. App. LEXIS 28085 (10th Cir. Sept. 3, 2020).

Defendant’s detention during the traffic stop was reasonable, and the plain view was valid. State v. Howard, 2020 Ida. App. LEXIS 66 (Sept. 3, 2020).*

While executing a search warrant, a cell phone that was likely to have incriminating evidence on it was seen in plain view. Lopezgamez v. State, 2020 Tex. App. LEXIS 7208 (Tex. App. – Ft. Worth Sept. 2, 2020).*