The driver consented to a search of the car defendant was a passenger in. The passenger’s purse was reasonably believed to be the driver’s for consent purposes, even though it was on her side. When it was opened and her ID was found, the drugs inside were in plain view. State v. Andera, 307 Neb. 686 (Oct. 30, 2020).
Defendants’ concessions during their suppression hearing about what should be suppressed constituted waiver when they changed their argument on appeal. United States v. Garcia, 2020 U.S. App. LEXIS 34402 (6th Cir. Oct. 30, 2020).
Defendant’s live-in girlfriend made a domestic violence call and invited the police in. Her consent entry and then protective sweep revealed marijuana. A search warrant was obtained, and it was valid. The mistake that the marijuana was found on the kitchen table (where it had been moved to when found in the bedroom) wasn’t material. United States v. Gray, 2020 U.S. App. LEXIS 34400 (6th Cir. Oct. 30, 2020).*