Defendant was arrested for a sex offense, and his search incident produced three microSD cards that fell to the ground. They were properly seized and then searched with a warrant finding child porn. Lewis v. State, 2023 Ark. 12, 2023 Ark. LEXIS 33 (Feb. 16, 2023).
Defendant’s ineffectiveness claim on failure to raise a search issue fails for lack of standing and on the merits. United States v. Dillon, 2023 U.S. App. LEXIS 3578 (7th Cir. Feb. 15, 2023).*
The motion to suppress the blood draw here was based on the implied consent statute, not the Fourth Amendment, so that argument isn’t before the court of appeals. Buonanotte v. State, 2023 Fla. App. LEXIS 962 (Fla. 4th DCA Feb. 15, 2023).