The search of text messages on a state administrative enforcement officer’s state issued cell phone was reasonable under City of Ontario v. Quon. Tingle v. Hebert, 2020 U.S. App. LEXIS 26057 (5th Cir. Aug. 17, 2020).
Defendant’s renting a car for $630 to drive overnight from Orlando to rural North Carolina and back in one day along with nervousness was enough for reasonable suspicion. United States v. Villavicencio, 2020 U.S. App. LEXIS 26033 (4th Cir. Aug. 17, 2020).*
Whether by probable cause and the automobile exception or inventory, the search of defendant’s car was reasonable and valid. United States v. Russell, 2020 U.S. Dist. LEXIS 147647 (M.D. Ala. July 10, 2020).*