OH1: Telling def to keep his hands out of his pockets and then put them on hood when he wouldn’t didn’t taint later consent

During a stop, defendant was told to keep his hands out of his pockets, but he didn’t and he was fidgeting and putting his hands in and out. Telling him to put his hands on the hood after all that was reasonable and didn’t make his subsequent consent involuntary. State v. Richardson, 2021-Ohio-2751, 2021 Ohio App. LEXIS 2710 (1st Dist. Aug. 11, 2021).*

Defendant had no reasonable expectation of privacy in his IP address logs under Carpenter. United States v. Herrington, 2021 U.S. Dist. LEXIS 150311 (D.Vt. Aug. 9, 2021).

Defendant’s use of email addresses was nexus to those accounts for a warrant that was otherwise issued with probable cause. United States v. Kovacs, 2021 U.S. Dist. LEXIS 150397 (N.D.Ohio Aug. 9, 2021).*

“The police here did not convey a message that Johnson was required to answer their questions. They arrived in plain clothes in a single unmarked car, without activating sirens or lights, displaying guns, or ordering Johnson to turn off his car or to remain inside. The lack of traditional signals of police authority and the absence of any coordinated effort among multiple police cars to confine Johnson distinguish Johnson’s case from those he cites.” United States v. Johnson, 2021 U.S. App. LEXIS 23815 (7th Cir. Aug. 11, 2021).*

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