Plaintiff’s complaint that his arrest was without probable cause doesn’t necessarily implicate his guilt or innocence, and it isn’t barred by Heck. He doesn’t even mention the conviction. Dizzley v. Garrett, 2021 U.S. App. LEXIS 4314 (4th Cir. Feb. 16, 2021).
Defendant was reported by a non-law enforcement witness to say she didn’t have time to consent to a warrantless search; even if it was a comment on her exercise of rights, it was admissible to show she was fully cooperative. United States v. Myres, 2021 U.S. App. LEXIS 4288 (9th Cir. Feb. 16, 2021).*
A warrant check on the passenger extended the stop, but it was with reasonable suspicion (without deciding the reasonableness of the warrant check without reasonable suspicion). United States v. Burrus, 2021 U.S. App. LEXIS 4295 (3d Cir. Feb. 16, 2021).*