VT: No reasonable expectation of privacy that co-conspirator wouldn’t let police listen to call

In a conspiracy to commit murder, defendant had no reasonable expectation of privacy in her telephone call with a co-conspirator that an officer was listening to. State v. Wetter, 2011 VT 111, 190 Vt. 476, 35 A.3d 962 (2011).*

Defendant’s consent to search a car includes her purse in the car. Her argument that the state constitution should be interpreted more broadly was not preserved in the trial court by any kind of cogent argument. State v. Lamonda, 2011 VT 101, 190 Vt. 618, 30 A.3d 687 (2011).*

When defendant was stopped for a traffic offense, there was a strong odor of alcohol, but the officer excluded that it was coming from defendant, the sole occupant of the car. Thus, there was probable cause to believe there was an open container in the car, and that justified a search. State v. Stevenson, 46 Kan. App. 2d 474, 262 P.3d 689 (2011).*

Nervousness, evasive answers to travel plans, few clothes, and an energy drink were reasonable suspicion. State v. Deviley, 2011 ND 182, 803 N.W.2d 561 (2011).*