Defendant was fired from his job and the manager consented to a search of the desk he used that was shared with others. There was no lock on the desk. Kelly v. State, 77 So. 3d 818 (Fla. App. 4th DCA 2012).

Defendant did not show that his stop was unreasonably prolonged for consent. Sims v. State, 313 Ga. App. 544, 722 S.E.2d 145 (2012)* [Note: This opinion is badly written and comes dangerously close to putting the burden on the defendant to show a warrantless detention was unreasonable.]

The search of defendant’s car was shown to be by consent, and the court does not accept that the atmosphere was generally coercive. Berry v. State, 2012 Ga. App. LEXIS 13 (January 12, 2012).*

At least in the Sixth Circuit, municipal ordinances are subject to judicial notice, and the government didn’t have to prove it as cause for a stop. There was cause to believe defendant violated a municipal ordinance for his stop. United States v. Alexander, 467 Fed. Appx. 355, 2012 FED App. 0025N (6th Cir. 2012) (unpublished).*

The entry into plaintiff’s home under the community caretaking function to retrieve weapons was not clearly unconstitutional, so the officers have qualified immunity. SCOTUS has yet to speak to it. Feis v. King County Sheriff’s Dep’t, 165 Wn. App. 525, 267 P.3d 1022 (2011)*:

¶32 At the time of Feis's arrest, the question of whether community caretaking could justify a warrantless entry of Feis's home under the circumstances attendant to this particular type of domestic dispute was not clearly established beyond debate. “Where no controlling authority specifically prohibits a defendant's conduct, and when the federal circuit courts are split on the issue, the law cannot be said to be clearly established.” Morgan, 659 F.3d at 372 (citing Wilson v. Layne, 526 U.S. 603, 617-18, 119 S. Ct. 1692, 143 L. Ed. 2d 818 (1999)). Since Cady v. Dombrowski, 413 U.S. 433, 93 S. Ct. 2523, 37 L. Ed. 2d 706 (1973), wherein the Court foreshadowed the current uncertainty regarding community caretaking by discussing the “constitutional difference” between vehicles and houses, the Supreme Court has not elaborated on whether or when the community caretaking exception may justify warrantless entry into a home. Cady, 413 U.S. at 441; see United States v. Gillespie, 332 F. Supp. 2d 923, 929 (W.D. Va. 2004). As a result, the federal circuits are not in agreement on the precise contours of the community caretaking exception. See Ray v. Township of Warren, 626 F.3d 170, 175-76 (3rd Cir. 2010) (“There is some confusion among the circuits as to whether the community caretaking exception set forth in Cady applies to warrantless searches of the home.”). Some federal courts condone resort to the community caretaking exception as an independent justification for a warrantless search of a private residence, while others do not. Because the extent, scope, and applicability of the community caretaking doctrine itself was not settled at the time of the search of Feis's home, the law was certainly not clearly established such that the deputies' actions here were unlawful beyond debate.

While defendant had permission to use an open field by a relative, that did not give him a reasonable expectation of privacy in what was nothing more than an abandoned refrigerator containing some drugs. United States v. Douglas, 2012 U.S. Dist. LEXIS 3673 (D. Minn. January 11, 2012)*:

As [U.S.M.] Judge Brisbois recognized, the most closely analogous precedent in the Eighth Circuit is United States v. Stallings, 28 F.3d 58 (8th Cir. 1994). In Stallings, the Eighth Circuit found that the defendant (Stallings) did not have a subjective expectation of privacy in a tote bag that he had left in the underbrush of a field belonging to his neighbor. Stallings, 28 F.3d at 59-61. The Eighth Circuit emphasized that the tote bag "bore no indicia of ownership indicating it belonged to Stallings," id. at 61 n.4, and, moreover, that Stallings had "put on no evidence of his possession or control of the bag, his historical use of the tote bag, or his ability or attempts to regulate access to it." Id. at 60-61. The Eighth Circuit further observed that, even if Stallings had a subjective expectation of privacy, it would not have been a reasonable expectation because Stallings, by leaving the bag in an open field unattended, had no means of restricting access to the bag. Id. at 61 ("[A]ny expectation of privacy Stallings had is not objectively reasonable ... because 'animals, children, scavengers, snoops, and other members of the public' had access to the tote bag.") (quoting California v. Greenwood, 486 U.S. 35, 40 (1988)).

Police received a suspicious vehicle report from a McDonald’s near an interstate that had been robbed before. They found two people asleep who gave nonsensical explanations and the license of the vehicle did not exist. It all added up to reasonable suspicion. The request for consent and giving it was valid. United States v. Espinal, 2011 U.S. Dist. LEXIS 151179 (N.D. Ga. August 29, 2011).*