Years old information of drug dealing in another county coupled with a trash pull of recent drug use (not trafficking) was stale, and the search warrant was clearly lacking probable cause. Therefore, the good faith exception does not apply. State v. Martin, 2021-Ohio-2599, 2021 Ohio App. LEXIS 2588 (1st Dist. July 30, 2021) (2-1).
A trooper’s traffic stop of defendant based on the community caretaking function was based on a report that the driver had just fallen asleep at an intersection. Texas applies both subjective and objective review of community caretaking function stops, and this satisfied both. Ramirez v. State, 2021 Tex. App. LEXIS 6136 (Tex. App. – El Paso July 30, 2021).
The time it took to complete the traffic stop, all things considered, was reasonable on the totality, and the dog sniff completed by the 18 minute mark didn’t extend it. State v. Jones, 2021-Ohio-2621, 2021 Ohio App. LEXIS 2578 (6th Dist. July 30, 2021).*