{"id":8952,"date":"2014-01-15T08:07:36","date_gmt":"2013-06-27T07:10:39","guid":{"rendered":""},"modified":"-0001-11-30T00:00:00","modified_gmt":"2013-06-27T07:10:39","slug":"en-US","status":"publish","type":"post","link":"http:\/\/fourthamendment.com\/?p=8952","title":{"rendered":"MO: Hot pursuit into IL and search incident was valid by MO officers"},"content":{"rendered":"<p>Defendant was accused of stealing a laptop bag from a bait car in St. Louis MO, and he fled into East St. Louis, IL with officers in pursuit. He was stopped and searched there. Illinois and Missouri both apply the conflict of laws rule that the law of the place of the search applies, and here it is the same. The hot pursuit was valid, as was the search in Illinois when defendant was stopped. <a href=\"http:\/\/www.courts.mo.gov\/file.jsp?id=62964\">State v. Williams<\/a>, 409 S.W.3d 428 (Mo. App. 2013).<\/p>\n<p>A federally licensed firearms dealer was burglarized, and defendant sold one of the guns stolen during the burglary. ATF got a search warrant for his house for firearms, and located more. While they were there, it was apparent defendant was a suspect in home invasion robberies, so ATF applied for an additional search warrant for evidence of that. The supplemental search warrant showed probable cause and nexus and was validly issued. <a href=\"http:\/\/pacer.ca4.uscourts.gov\/opinion.pdf\/124130.U.pdf\">United States v. Scott<\/a>, 531 Fed. Appx. 283 (4th Cir. 2013).*<\/p>\n<p>Both defendants disavowed ownership of a cell phone found in a vehicle during a traffic stop, so the officer put it in his pocket. Later, a call came in and it was answered. The cell phone was abandoned property when it was searched. United States v. Gaona-Gomez, 2013 U.S. Dist. LEXIS 89517 (S.D. Tex. June 26, 2013).*<\/p>\n","protected":false},"excerpt":{"rendered":"<p>b2evALnk.b2WPAutP <a class=\"more-link\" href=\"http:\/\/fourthamendment.com\/?p=8952\">Continue reading <span class=\"meta-nav\">&rarr;<\/span><\/a><\/p>\n","protected":false},"author":3,"featured_media":0,"comment_status":"","ping_status":"pingsdone","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[],"tags":[],"class_list":["post-8952","post","type-post","status-publish","format-standard","hentry"],"_links":{"self":[{"href":"http:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/posts\/8952","targetHints":{"allow":["GET"]}}],"collection":[{"href":"http:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/posts"}],"about":[{"href":"http:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"http:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/users\/3"}],"replies":[{"embeddable":true,"href":"http:\/\/fourthamendment.com\/index.php?rest_route=%2Fwp%2Fv2%2Fcomments&post=8952"}],"version-history":[{"count":0,"href":"http:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/posts\/8952\/revisions"}],"wp:attachment":[{"href":"http:\/\/fourthamendment.com\/index.php?rest_route=%2Fwp%2Fv2%2Fmedia&parent=8952"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"http:\/\/fourthamendment.com\/index.php?rest_route=%2Fwp%2Fv2%2Fcategories&post=8952"},{"taxonomy":"post_tag","embeddable":true,"href":"http:\/\/fourthamendment.com\/index.php?rest_route=%2Fwp%2Fv2%2Ftags&post=8952"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}