OR: Illegal detention led to invalid consent

Illegal detention led to invalid consent. Defendant showed the necessary minimal connection, and the state could not show that it did not exploit that illegality. State v. Ayles, 348 Ore. 622, 237 P.3d 805 (2010).*

Defense counsel was not ineffective for not challenging the search of defendant because there was probable cause for his arrest. Brown v. State, 3 A.3d 1096 (Del. 2010).*

Defendant drove past a police officer who knew that there was a warrant for his arrest. He was followed to a convenience store where he was arrested. A police officer shined a flashlight into the car and saw a baggy of crack in plain view, and that justified an automobile exception search of the car. Suppression order reversed. State v. Sarden, Ga. App. 587, 699 S.E.2d 880 (2010).*

The search of defendant’s car did not violate Gant where he fought with the officer and fled from the car as the officer attempted to handcuff him, leaving the door open. This was an abandonment. Johnson v. State, 305 Ga. App. 635, 700 S.E.2d 612 (2010).*

Defendant was stopped for reckless driving, and the officer smelled marijuana coming from the car. Defense counsel was not ineffective for not challenging the search. Mason v. State, 42 So. 3d 629 (Miss. App. 2010).*