GA: Police reentry into hotel room after medical emergency required SW

Officers responded to a medical emergency at a hotel room. They left and reentered to seize contraband, and the reentry required a warrant. The exigency had passed. State v. Wood, 2023 Ga. App. LEXIS 101 (Feb. 28, 2023).

The suppression hearing occurred before a circuit clarification on private search law, so the case is remanded for more findings. United States v. Bohannon, 2023 U.S. App. LEXIS 4574 (9th Cir. Feb. 24, 2023).*

Defendant could not cross the officer at trial with the affidavit for search warrant under F.R.E. 613(b) because it wasn’t irreconcilably different and he didn’t testify to anything about it. United States v. Duerson, 2023 U.S. Dist. LEXIS 31879 (E.D. Ky. Feb. 27, 2023).

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