WI: Officer inquiring of pill bottle in plain view during traffic stop did not unreasonably extend stop

Officer in a traffic stop inquiring of a pill bottle in plain view wasn’t unreasonable under Rodriguez. State v. Crone, 2021 Wisc. App. LEXIS 192 (Apr. 20, 2021).

The officer’s sticking his head inside defendant’s car and smelling marijuana was probable cause for an automobile exception search. United States v. O’Grady, 2021 U.S. Dist. LEXIS 74692 (N.D. Ind. Apr. 19, 2021).*

Defense counsel wasn’t ineffective for not raising Carpenter before it was decided. Terrell v. State, 2021 Ark. App. 179, 2021 Ark. App. LEXIS 186 (Apr. 21, 2021).*

A field sobriety test requires reasonable suspicion. “In the present case, there is an abundance of articulable facts to support any reasonably prudent law enforcement officer’s suspicion that Lyndon had operated a vehicle while intoxicated.” State v. Lyndon, 2021-Ohio-1370, 2021 Ohio App. LEXIS 1334 (11th Dist. Apr. 19, 2021).*

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