A prior controlled buy with defendant showing up for another one justifies a vehicle search under the automobile exception. United States v. Smith, 2021 U.S. App. LEXIS 6166 (7th Cir. Mar. 3, 2021).
The trial court credited the officer’s testimony that a computer warrant check on defendant received a positive response. The dashcam audio only confirmed it. The vehicle was searched for inventory before towing. State v. Scofield, 2021-Ohio-569, 2021 Ohio App. LEXIS 590 (5th Dist. Mar. 1, 2021).*
Defense counsel pursued two motions to suppress in defendant’s case but did not allege lack of particularity. That was treated here as a strategic choice. Moreover, defendant doesn’t even attempt to show that the argument would have prevailed if made. Roy v. United States, 2021 U.S. Dist. LEXIS 39964 (S.D. Fla. Mar. 2, 2021).*