There no longer was exigency, in part here from the police delay in responding to 911 call, and what was observed was innocuous. No exigency on the totality. Cotten v. Miller, 2022 U.S. Dist. LEXIS 139360 (D. Minn. Aug. 5, 2022).*
Defendant was on supervised release, and he was stopped for a traffic offense. He produced another person’s driver’s license. This permitted a Gant search incident for his own driver’s license around where he was sitting. That produced a THC vape. Further search of the car under the automobile exception produced a backpack which he disavowed. Inside was more drugs. United States v. Pinder, 2022 U.S. Dist. LEXIS 139354 (D. Utah Aug. 4, 2022).
Defendant didn’t have ineffective assistance of counsel because defense counsel didn’t file a notice of supplemental authority with a later case that wouldn’t have changed the outcome. United States v. Aigbekaen, 2022 U.S. Dist. LEXIS 139367 (D. Md. Aug. 3, 2022).*