IA: Trash container in the grass on the alley within easy reach was searchable

In a trash search case, the trash cans faced an alley but were on defendant’s grass. The officers could open the trash cans without stepping on the property. This was a valid trash search, and, having credited the officers’ testimony, there was no trespass or violation of the curtilage. State v. Grimm, 2021 Iowa App. LEXIS 9 (Jan. 21, 2021).

The search warrant was supported by probable cause so defense counsel wasn’t ineffective for not challenging it. United States v. Sample, 2021 U.S. Dist. LEXIS 11994 (W.D. Pa. Jan. 22, 2021).*

Plaintiff didn’t state a claim for invasion of privacy or unreasonable search because he didn’t have an expectation of privacy invaded by a police officer standing near his car when he came from a city council meeting. Danielson v. South Dakota, 2021 U.S. Dist. LEXIS 11244 (D.S.D. Jan. 21, 2021).*

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