A Simmons error of use of defendant’s suppression hearing testimony showing standing and control over the place searched was not subject to plain error analysis. An objection is required. Commonwealth v. Taylor, 2015 Ky. LEXIS 2012 (Dec. 17, 2015):
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“[T]he anonymous tip upon which Detective Harrison relied merely provided a range of details relating to easily obtained facts and conditions existing at the time the tip was made. ‘[T]he anonymous tip did not contain facts which are ordinarily not easily predicted but which would have demonstrated a familiarity with [James]’s affairs that the general public would not have had, [and Detective Harrison did] not corroborate[] the tip by independent investigation sufficient to furnish reasonable suspicion that [James] was engaged in criminal activity.’ Barnette, 624 So. 2d at 509. Because Detective Harrison detained James based on nothing more than an uncorroborated anonymous tip with little indicia of reliability, James’s right under the Fourth Amendment to be free of unreasonable seizures was violated. Further, the discovery of the drug evidence was a direct result of James’s unconstitutional detention; therefore, the circuit court erred by denying James’s motion to suppress.” James v. State, 2015 Ala. Crim. App. LEXIS 110 (Dec. 18, 2015).

A CI working for the DEA and state officers made a deal with defendant to deliver 15kg of cocaine at a truck stop in Birmingham. Officers watched and videorecorded the transfer and followed the vehicle with the cocaine until they decided to make the arrest. They had probable cause to stop and search it under the automobile exception. [The only remarkable thing about this is that the trial judge actually found no probable cause.] State v. Breeding, 2015 Ala. Crim. App. LEXIS 108 (Dec. 18, 2015).*