Defendant who walked into an apartment being searched under a warrant could be searched himself, including the grocery bag he was carrying. People v. Matthias, 2021 V.I. LEXIS 23 (Apr. 30, 2021).
Defendant’s backpack in the car couldn’t be searched incident to his arrest when he was secured outside the car. United States v. Davis, 2021 U.S. App. LEXIS 13676 (4th Cir. May 7, 2021).
“[W]e conclude that Shropshire impermissibly interrogated defendant by asking him to perform the FSTs after he invoked his Miranda rights. The motion to suppress must be granted, and the trial court erred in concluding otherwise.” State v. Shevyakov, 311 Or. App. 82, 2021 Ore. App. LEXIS 604 (May 5, 2021).*