County of Riverside v. McLaughlin’s 48 hour rule does not apply to parole holds. Benson v. Chappell, 2020 U.S. App. LEXIS 14035 (9th Cir. May 1, 2020).
There was reasonable suspicion for defendant’s stop, but the officer’s opening the car door was a search without probable cause. Only then did the officer smell marijuana. Search suppressed. People v. Johnson, 2020 NY Slip Op 02589, 2020 N.Y. App. Div. LEXIS 2600 (4th Dept. May 1, 2020).