D.Haw.: Specific exigency not required for automobile exception search

Defendant’s car could be searched under the automobile exception while it was parked at his mother’s condo. Exigency isn’t specifically required. United States v. Chan, 2023 U.S. Dist. LEXIS 14062 (D. Haw. Jan. 27, 2023).*

Even if defendant’s otherwise objectively reasonable stop for going 66 in a 65 zone was pretextual, there was reasonable suspicion on the totality based on a debriefing earlier that day that showed defendant was involved in carrying drugs. United States v. Holton, 2023 U.S. Dist. LEXIS 14264 (D.S.D. Jan. 25, 2023).*

Three CIs gave information on defendant, and one said he’d be at a storage unit in his “slick looking Infinity SUV” and “doing big things.” They watched him at the storage unit. During a stop, they asked about the storage unit, and he lied about being at Taco Bell instead. All that added up to reasonable suspicion to extend the stop. State v. Ball, 2023-Ohio-235, 2023 Ohio App. LEXIS 228 (5th Dist. Jan. 27, 2023).*

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