Defendant’s probation officer wasn’t present for his probation search, and that was required at the time by state law (since changed but prospectively). Still, that voided his probation search. State v. Carter, 2019 La. App. LEXIS 1152 (La. App. 2 Cir. June 26, 2019).
An officer came to defendant’s house to talk to him about something unrelated to drugs. He smelled marijuana coming from the house and later did a trash search. That led to a search warrant for the premises which was valid. Commonwealth v. Handley, 2019 PA Super 201, 2019 Pa. Super. LEXIS 638 (June 28, 2019).*