Defendant’s arrest didn’t remove the safety factor because there were others in the vehicle who could access a potential weapon. Therefore, the search for the weapon was reasonable. Commonwealth v. Silvelo, 2020 Mass. LEXIS 647 (Oct. 14, 2020).
Defendant filed a motion to suppress the contents of a cell phone of another searched without a warrant. The motion wasn’t taken up before trial. He raised the issue again during trial, and the trial court denied it. On appeal, the evidence at trial is all the court has, and that shows he lacked standing in the cell phone of another: The photos and text messages by and about the other person. Martinez v. State, 2020 Tex. App. LEXIS 8113 (Tex. App. – Austin Oct. 14, 2020).*