OR: Stop of def for being either involved in accident or material witness to it lacked RS

Defendant was in a vehicle that passed by the scene of a one vehicle accident the police were working. The officer somehow decided that the occupants of the passing vehicle had knowledge of the stop, and he engaged in a significant show of authority. That stop was without reasonable suspicion or even that defendant was a material witness to the accident. The motion to suppress should have been granted. State v. Middleton, 302 Ore. App. 339 (Feb. 20, 2020).

DOC employees have a reasonable expectation of privacy in their employment records as to outsiders, but not the agency itself. It can monitor employee performance. Speer v. State, Dept. of Corrections, 2020 MT 45, 2020 Mont. LEXIS 578 (Feb. 25, 2020).

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