The search of defendant’s jacket pockets when he was arrested was valid under the search incident doctrine even though he was handcuffed. United States v. Coates, 2021 U.S. Dist. LEXIS 232798 (S.D.Ind. Dec. 6, 2021).
Defendant had a right to a state Pirtle warning before a consent search of a hotel room. The state failed to prove voluntary consent. Posso v. State, 2021 Ind. App. LEXIS 366 (Nov. 30, 2021).
Defendant was the subject of a search warrant and order for delivery of cell phone GPS information. It wasn’t a constitutional violation to provide only the order to the provider. The exclusionary rule was not intended for this. United States v. Magruder, 2021 U.S. Dist. LEXIS 233102 (D.D.C. Dec. 6, 2021).*