Defendant was a visitor at a friend’s house when the house was searched under a warrant for drugs. She was on the couch with a meth pipe next to her, so it was reasonable to search her lockbox under the warrant for the host’s premises. “This was enough to give officers “particularized suspicion” that Simmermaker was connected to the illicit activity that provided the basis for the warrant.” United States v. Simmermaker, 2021 U.S. App. LEXIS 16238 (8th Cir. June 1, 2021).
The inventory policy here was specific and articulated in the proof, and there was no indication the inventory was a pretext for criminal investigation. United States v. Thibeault, 2021 U.S. App. LEXIS 16258 (10th Cir. June 1, 2021).*
In an illegal entry case, identity evidence is generally not suppressible. United States v. Hernandez-Pacheco, 2021 U.S. App. LEXIS 16304 (11th Cir. June 1, 2021).*