Defendant argues that the inventory was pretextual to search for evidence of crime, except that there already was probable cause at that point for an automobile exception search. On a later vehicle search, there also was a warrant. Failing to challenge the search warrant for the car obviates the automobile exception. United States v. Phillips, 2022 U.S. Dist. LEXIS 7162 (N.D.Okla. Jan. 13, 2022).
Information about defendant’s LPN captured by a license plate reader didn’t violate any reasonable expectation of privacy under Jones or Carpenter. United States v. Porter, 2022 U.S. Dist. LEXIS 6755 (N.D.Ill. Jan. 13, 2022).
Defendant didn’t appeal from the order sealing a search warrant so it can’t be considered. State v. Justice, 2022-Ohio-87, 2022 Ohio App. LEXIS 65 (10th Dist. Jan. 13, 2022).