OR: A metal box next to def when stopped was subject to search incident here

Even under Oregon’s restrictive search incident doctrine, the search of a metal box next to defendant was reasonable. She was suspected of stealing from a Salvation Army donations trailer when she was stopped. Practically anything in her vehicle looked like it could have come from there. State v. Edwards, 319 Ore. App. 60, 2022 Ore. App. LEXIS 637 (Apr. 13, 2022).

Straddling the fog line more than just briefly justified this stop. State v. Murphy, 2022 Iowa App. LEXIS 281 (Apr. 13, 2022).*

The officer was alerted to defendant’s car by dispatch passing on an anonymous tip. Then the officer observed him swerve four times out of the lane, so the stop was justified. State v. McLaughlin, 2022-Ohio-1227, 2022 Ohio App. LEXIS 1123 (5th Dist. Apr. 12, 2022).*

Defendant’s CSLI claim about 2006 capture of three days of information was unpreserved. State v. Tyus, 2022 Conn. LEXIS 81 (Apr. 12, 2022).*

The reasonable suspicion for defendant’s stop was the officer’s belief that the driver of the car was involved in violation of a no contact order. Three bags on one side of the backseat is not reasonable suspicion. United States v. Skarja, 2022 U.S. Dist. LEXIS 67598 (D.Minn. Apr. 12, 2022).*

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