D.Mass.: Inevitable discovery applies to def giving up passcode to cell phone

Inevitable discovery applies to defendant giving up the passcode to his cell phone by a statement he challenged. The government had an independent basis to get into the phone to search it. United States v. Xiaolei Wu, 2024 U.S. Dist. LEXIS 7511 n.3 (D. Mass. Jan. 16, 2024).

Defendant’s patdown was based in significant part on suspicion he was intoxicated. But it turned out he wasn’t, and then he lied about his identity justifying the detention. United States v. Ahrendt, 2024 U.S. Dist. LEXIS 7243 (D.S.D. Jan. 11, 2024).*

The smell of marijuana and other suspicious circumstances gave probable cause to search defendant’s car and a Crown Royal bag found inside. State v. Springs, 2024 N.C. App. LEXIS 54 (Jan. 16, 2024).*

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