While defendant argued that his stop was pretextual, there was a factual basis for it, and his consent, after he was Mirandized, was voluntary. State v. Mathis, 204 S.W.3d 247 (Mo. App. E.D. September 5, 2006).

Motion to suppress was granted. Merely passing something into a car in exchange for money is not indicative of drug activity. This was not in a known drug area. People v. Walters, 2006 N.Y. Misc. LEXIS 2324, 236 N.Y.L.J. 40 (Nassau Co. August 17, 2006).

Defendant’s alleged illegal arrest and obtaining of his statements did not require suppression of later statements where he was Mirandized, had refused consent, and then later became cooperative in the investigation. State v. Adame, 2006 NMCA 100, 142 P.3d 26 (June 14, 2006).

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