D.P.R.: PR nighttime search rules irrelevant in federal court

Puerto Rico cases on nighttime search aren’t relevant in federal court. United States v. Pastrana-Román, 2023 U.S. Dist. LEXIS 238527 (D.P.R. March 9, 2023),* adopted, 2024 U.S. Dist. LEXIS 106442 (D.P.R. May 17, 2024).*

Defendant didn’t show good cause for delaying in filing his motion to suppress until after the motion deadline. United States v. Bridges, 2024 U.S. App. LEXIS 14559 (7th Cir. June 14, 2024).*

Reasonable suspicion existed for defendant’s stop from not having headlights on in the rain and nearly hitting a pedestrian in a crosswalk. United States v. Colvin, 2024 U.S. App. LEXIS 14605 (3d Cir. June 17, 2024).*

“Here, the traffic stop was not unreasonably prolonged. It took Officer Gregston about six minutes to complete a records inquiry. Within minutes of encountering Austin, the officers had reasonable suspicion to investigate possible criminal activity beyond the traffic violation. The odor of marijuana, Austin’s furtive behaviors suggestive of an attempt to conceal something, and his admission that he had smoked marijuana earlier that day gave the officers reasonable suspicion to prolong the traffic stop.” United States v. Austin, 2024 U.S. App. LEXIS 14599 (8th Cir. June 17, 2024).*

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