In a federal criminal case, the fact the search violated the state constitution isn’t a factor on legality of the search under the Fourth Amendment. United States v. Breeden, 2021 U.S. Dist. LEXIS 145729 (E.D.N.C. Aug. 4, 2021).
Various factors about the package added up to reasonable suspicion to detain it in transit (weight, fictitious return address, likely drop at drug distribution point). United States v. Butler, 2021 U.S. Dist. LEXIS 145710 (E.D.Mich. Aug. 4, 2021).
Collective knowledge of the officers supported reasonable suspicion. United States v. Galloway, 2021 U.S. Dist. LEXIS 145795 (D.Nev. Aug. 4, 2021).*
Continuation of defendant’s stop under Heien was reasonable. “Again, based on the facts known to Officer Merritt at the time of the traffic stop including the stolen vehicle report filed at the request of Enterprise and the unique situation with two license plates registered to the same VIN, he could objectively reasonably believe, even mistakenly, that the van was stolen, thus warranting a traffic stop.” United States v. James, 2021 U.S. Dist. LEXIS 145852 (N.D.Iowa Aug. 4, 2021).*