S.D.Tex.: Inevitable discovery by inevitable SW obviated dispute over consent

Inevitable discovery also supports the consent search of defendant’s cell phone obtained at the Sarita, Texas checkpoint. The officers had probable cause and told him they’d get a search warrant and he consented instead. The matter was clearly under active investigation. United States v. Reyes-Herrera, 2021 U.S. Dist. LEXIS 101416 (S.D. Tex. May 28, 2021).*

Defendant’s objection to the R&R was general and pointed out no particular error, and thus there was no clear error. United States v. Latourell, 2021 U.S. Dist. LEXIS 101555 (D. Minn. May 28, 2021).*

Plaintiff’s Tasing during an apparent psychotic break when police were called a second time was objectively reasonable. Estate of Erwin v. Greene County, 2021 U.S. App. LEXIS 16102 (6th Cir. May 26, 2021).*

Directing defendant during a traffic stop to get out of the car and stand on the sidewalk was a detention, but it was reasonable. State v. Hampton, 2021-Ohio-1834, 2021 Ohio App. LEXIS 1787 (2d Dist. May 28, 2021).*