NV: The state’s ability to seize a cell phone with exigency doesn’t include the power to search it

The ability to seize a cell phone with exigent circumstances doesn’t include the state’s ability to search it without a warrant. Smith v. State, 2024 Nev. LEXIS 14 (Mar. 28, 2024).

Defendant wasn’t seized when the officer first approached him. Williamson v. United States, 2024 U.S. Dist. LEXIS 58157 (S.D. Fla. Mar. 29, 2024).*

“Once Lt. McConnell ascertained during the traffic stop that Tyree was illegally driving under an FRA/noncompliance suspension and that she had a prior DUS suspension, he was lawfully able (and required) to tow the vehicle.” The inventory was valid. State v. Tyree, 2024-Ohio-1186 (2d Dist. Mar. 29, 2024).*

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