W.D.Pa.: Opening car door and drug dog jumping in wasn’t encouraging the dog

During a dog sniff, the officer opened the car door, and the dog jumped in. The officer did not encourage the dog to enter [merely by opening the door], so this was not a search. The court notes that the smell of marijuana from the car was overwhelming. United States v. Humphries, 2020 U.S. Dist. LEXIS 225165 (W.D. Pa. Dec. 2, 2020).

An officer saw a Mercedes driving left of center. That officer radioed to another patrol unit to make a traffic stop. On seeing the patrol unit, defendant fled, wrecking the car. He bailed out and ran and fell and dropped something which he picked up. When he was stopped, he had drugs on him. The seizure was valid. Cribbs v. State, 2020 Ark. App. 539 (Dec. 2, 2020).*

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