CA4: Search incident of bag unreasonable where def handcuffed behind back and face down

Search of defendant’s bag when he was handcuffed behind his back and lying face down was unreasonable because it was unreachable. United States v. Buster, 2022 U.S. App. LEXIS 4747 (4th Cir. Feb. 22, 2022).

When omitted information is relied upon in an attempt to plead a Leon exception to good faith, an offer of proof is required to the district court. That did not happen here. Walker v. Park County Sheriff’s Office, 2022 U.S. App. LEXIS 4873 (10th Cir. Feb. 23, 2022).

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