After a motion to suppress was filed and briefed and the government responded, new issues in the reply brief are usually treated as waived. Here, however, the court will let him proceed on those issues and he can file a new brief. United States v. Johnson, 21-cr-332 (D.D.C. Dec. 15, 2021).
There was no showing that the police manipulated the automobile exception’s exigency requirement. State v. Hopkins, 316 Or. App. 466, 2021 Ore. App. LEXIS 1779 (Dec. 15, 2021) (under state constitution).*
Defendant was validly arrested with an immigration warrant, and then a search warrant was obtained for his cell phone seized during the arrest. United States v. Cisneros, 2021 U.S. Dist. LEXIS 239032 (N.D.Cal. Dec. 14, 2021).*