NE: Search of def’s car valid under automobile exception where he was late for third controlled buy

When defendant didn’t show up for his third controlled buy, police went to him and searched his car finding the drugs. They had probable cause for that search under the automobile exception. State v. Garza, 29 Neb. App. 223 (Dec. 8, 2020).

“Carson’s argument that Aurand’s investigation was unconstitutional because it was limited to her interview with S.W. is unavailing. ‘When a police officer has received a reliable identification by a victim of his or her attacker, the police have probable cause to arrest.’ …. Thus, S.W.’s identification of Carson was sufficient to provide probable cause. See Aurand Dep., ECF No. 32-6 at 25-26 (explaining that Aurand believed S.W. to be credible).” Carson v. Aurand, 2020 U.S. App. LEXIS 38330 (3d Cir. Dec. 9, 2020).