CA7: Pro se letter to court to preserve search claim wasn’t conditional plea

Defendant pled to the indictment, having written a letter to the court that he wanted to preserve his search claim. His pro se letter did not satisfy the conditional plea rule. United States v. Turner, 2022 U.S. App. LEXIS 35476 (7th Cir. Dec. 22, 2022).

This was a close call on reasonable suspicion, but, on the totality, the court can’t say that the stop was prolonged for the drug dog under existing circuit precedent. United States v. Guerue, 2022 U.S. Dist. LEXIS 230025 (D.S.D. Dec. 20, 2022).*

“In this case, the State established the decision to impound was made consistent with statutory authority in Section 304.155.1(5) and that the pre-impoundment inventory search was reasonable because the State was motivated by legitimate governmental concerns, not a desire to search for evidence.” State v. Creutz, 2022 Mo. App. LEXIS 821 (Dec. 21, 2022).*

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