CA6: Even if harassment was a basis to exclude a parole search, it wasn’t shown here

The exclusionary rule does not apply in supervised release revocation proceedings. Even if harassment by the officer was a basis to exclude, it wasn’t present here. United States v. Robinson, 2023 U.S. App. LEXIS 6756 (6th Cir. Mar. 21, 2023)* (court provides a long discussion of the needs for no exclusion in supervised release cases).

The request for consent to search defendant’s car came while the officer had at least reasonable suspicion defendant as driving under the influence, and it did not prolong the stop. United States v. Mancoll, 2023 U.S. Dist. LEXIS 46994 (E.D. Va. Mar. 20, 2023).*

Viewing the bodycam video, defendant was not seized nor in custody when he made incriminating statements. United States v. Shannon, 2023 U.S. Dist. LEXIS 47242 (S.D. Miss. Mar. 21, 2023).*

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