WY: Courthouse entry search valid under “special needs”

Defendant entered a courthouse, and the metal detector went off on a small can on him which he opened on request revealing meth. These searches are valid as “special needs.” Russell v. State, 2024 WY 126, 2024 Wyo. LEXIS 128 (Nov. 26, 2024).

“Fairweather alleges that he was stopped by Spathelf in April of 2023 for traffic violations, and that Spathelf subsequently searched his vehicle without consent or a warrant and without probable cause. Fairweather claims that the search yielded nothing illegal. Accordingly, construing the complaint liberally as we must, we conclude that Fairweather has sufficiently stated a Fourth Amendment claim against Spathelf arising out of the April 2023 search.” Fairweather v. Spathelf, 2024 U.S. Dist. LEXIS 214184 (M.D. Pa. Nov. 25, 2024).*

Defendant passenger was lawfully ordered from the car during a stop and he wasn’t in custody when he admitted to crossing the border illegally and didn’t need yet to be Mirandized. United States v. Martinez, 2024 U.S. Dist. LEXIS 214431 (D.N.M. Nov. 25, 2024).*

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