D.Vt.: Apt building parking lot not curtilage; def’s girlfriend was private searcher

Defendant’s vehicle was in an apartment building parking lot, and that’s not curtilage. There was also probable cause to search it and it was mobile. Defendant’s cell phone was privately seized from his vehicle and turned over to police by his domestic violence victim. United States v. Guillette, 2021 U.S. Dist. LEXIS 78454 (D. Vt. Apr. 23, 2021).

The search of defendant’s person at the station house was reasonable as inventory [or search incident]. He hadn’t been fully searched on the street. The gun found was admissible. United States v. Murrell, 2021 U.S. Dist. LEXIS 78344 (S.D. N.Y. Apr. 23, 2021).

The officer who investigated and arrested defendant was later prosecuted. Defendant doesn’t show that this had any relationship to the search warrant in his case. United States v. Becks, 2021 U.S. Dist. LEXIS 78551 (W.D. Va. Apr. 23, 2021).*

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