When heroin and cash were found in the search of a car based on the smell of marijuana, seizure of a notebook was reasonable. The notebook was limited information compared to a cell phone. United States v. Pierre, 2021 U.S. Dist. LEXIS 81917 (W.D. La. Apr. 29, 2021).
Defendant’s motion to suppress PBT results didn’t include the predicate probable cause issue, so it’s not before the court of appeals. People v. Robe, 2021 Mich. App. LEXIS 2716 (Mar. 18, 2021).
An open container in the back seat was reasonable suspicion for further inquiry and prolonging the stop. United States v. Patterson, 2021 U.S. App. LEXIS 12764 (6th Cir. Apr. 27, 2021).*
Defendant didn’t back up his Franks claim with an offer of proof, just an allegation. State v. Schubert, 2021-Ohio-1478, 2021 Ohio App. LEXIS 1467 (5th Dist. Apr. 28, 2021).*