Police arrived at a crowd on a parking lot in a high crime area. People were drinking in public and there was the smell of marijuana in the air, but none of that had anything to do with defendant. Thus, they had no reasonable suspicion for a detention and frisk of defendant. His motion to suppress should have been granted. State v. Mosby, 2021-Ohio-2255, 2021 Ohio App. LEXIS 2199 (6th Dist. June 30, 2021).
Defendant failed to show she was in custody at the time she made voluntary statements. Wexler v. State, 2021 Tex. Crim. App. LEXIS 630 (June 30, 2021).*
Defendant has no post-conviction IAC search claim because he shows no standing to contest the search. State v. Culberson, 2021-Ohio-2214, 2021 Ohio App. LEXIS 2174 (2d Dist. June 30, 2021).*
“Our task is to determine whether those facts, when viewed in their totality, objectively support Boyd’s suspicion that defendant had engaged in a drug transaction. We conclude that, although none of the facts articulated by Boyd are sufficient on their own, when viewed in their totality, the facts known to Boyd give rise to reasonable suspicion.” State v. Hollins, 312 Or. App. 682, 2021 Ore. App. LEXIS 901 (June 30, 2021).*