The state at first didn’t rely on Summers and Bailey for proximity to the place searched for detaining and searching defendant. The trial court suggested it. Then they didn’t prove sufficient proximity to justify the stop. State v. Rolon, 2020 Conn. LEXIS 281 (Nov. 13, 2020).
“Moreover, a Fourth Amendment violation is a non-jurisdictional defect that is waived pursuant to a valid guilty plea.” In re Jelks, 2020 U.S. App. LEXIS 36010 (6th Cir. Nov. 16, 2020).
The product of the search in this case was cumulative to other evidence in the case, so it is harmless error, even if it was error. Lopez v. State, 2020 Tex. App. LEXIS 8910 (Tex. App. – El Paso Nov. 17, 2020).*