SC: Failure to specify place to be searched was cured by attached affidavit

Where the warrant failed to describe the place to be searched but the affidavit did and was attached, the papers as a whole properly described the place to be searched. State v. Cheeks, 400 S.C. 329, 733 S.E.2d 611 (2012).

The trial court held that the officer failed to show that a traffic violation occurred and suppressed the search based on that stop. The video of the stop did not contradict the trial court’s findings, so they are affirmed. State v. Houghton, 384 S.W.3d 441 (Tex. App. – Ft. Worth 2012).

Defendant argued that the inventory policy for no insurance was too discretionary with the officer. Here, however, the vehicle was parked so it impeded traffic, so the inventory was proper because the vehicle was towed for that without regard to possible pretext. State v. Penney, 252 Ore. App. 677, 288 P.3d 989 (2012).*