M.D.La.: Automobile exception doesn’t apply to car parked in owner’s garage

Under Collins, the automobile exception does not apply to a car parked in the owner’s garage. United States v. Dejoie, 2024 U.S. Dist. LEXIS 64270 (M.D. La. Apr. 8, 2024).

“The exclusionary rule does not apply to ‘physical evidence that is the fruit of custodial interrogation conducted without Miranda warnings.’” United States v. Root, 2024 U.S. Dist. LEXIS 63705 (N.D. Iowa Apr. 8, 2024)* (citing Pantane).

“Francis had all this information no later than four minutes into the stop. During that time frame, he had diligently undertaken tasks necessary to complete a traffic infraction investigation. Before all those tasks could be completed, he had reasonable suspicion to detain Caraballo pending a dog sniff of the vehicle.” United States v. Caraballo, 2024 U.S. Dist. LEXIS 64486 (D. Conn. Apr. 9, 2024).*

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