OH11: Driver not matching owner of car not RS

Just because the driver isn’t the owner doesn’t mean the car is stolen. See Kansas v. Glover. This was extending the stop without reasonable suspicion. State v. Dunlap, 2022-Ohio-3007, 2022 Ohio App. LEXIS 2828 (11th Dist. Aug. 29, 2022); State v. Lewis, 2022-Ohio-3006, 2022 Ohio App. LEXIS 2833 (11th Dist. Aug. 29, 2022).

A search warrant was properly used to get CSLI connecting defendant to a robbery-murder. United States v. Holden, 2022 U.S. Dist. LEXIS 154916 (N.D. Ind. Aug. 29, 2022).*

Plaintiff’s civil Franks claim fails because there was probable cause without it. Laviage v. Fite, 2022 U.S. App. LEXIS 24333 (5th Cir. Aug. 29, 2022).*

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