Defendant left his house, went to a drug deal, and returned. This is not the officer’s mere reliance on what drug dealers normally do or he would expect to find. United States v. McCreary, 2022 U.S. Dist. LEXIS 69838 (N.D.Ill. Apr. 15, 2022).
At the end of a 25 minute traffic stop, defendant first consented to a search of his vehicle, but then revoked it. By then, however, the officer had probable cause and the search warrant for the car. United States v. Rosales, 2022 U.S. Dist. LEXIS 68459 (D.Mont. Apr. 12, 2022).*
Defendant’s motion to suppress wasn’t timely, and it’s forfeited. On the merits, the inventory here was valid despite the officer’s subjective intent. United States v. Gibson, 2022 U.S. Dist. LEXIS 68740 (E.D.Tex. Apr. 13, 2022).*
Officers executed a search warrant on defendant’s apartment. Officers told him he was free to leave, but he stuck around and talked. He wasn’t in custody and the statements were voluntary. United States v. Fonseca, 2022 U.S. Dist. LEXIS 69846 (N.D.Ill. Apr. 15, 2022).*
The court credits that the firearm here was in plain view sticking out from under the driver’s seat. United States v. Wagoner, 2022 U.S. Dist. LEXIS 69753 (W.D.Va. Apr. 14, 2022).*