IA: Automobile exception search of glove compartment here was unreasonable

Search of the glove compartment is reasonable to look for evidence of ownership of a car already subject to search, but that wasn’t an issue here because there was no reason to. State v. Marcott, 2022 Iowa App. LEXIS 385 (May 11, 2022).

“The record demonstrates that Detective Thomas had a particularized, objectively reasonable basis to conclude that Byrd specifically may have been armed at the time she conducted the weapons pat down.” United States v. Byrd, 2022 U.S. Dist. LEXIS 84238 (E.D.Ky. Apr. 29, 2022),* R&R, 2022 U.S. Dist. LEXIS 58253 (E.D.Ky. Mar. 30, 2022).*

“The SCA allows only the Government to seek electronically stored communications from internet providers. … The Supreme Court has held that a government entity may compel an internet provider to produce information under the SCA, consistent with the Fourth Amendment. See generally Carpenter v. United States, …. A court within this district has held that public defenders do not qualify as a government entity under the SCA. See United States v. Amawi, 552 F.Supp.2d 679, 680 (N.D. Ohio 2008). This court agrees and accordingly determines that the SCA does not permit Defendant to subpoena Meta for information related to Decedent.” United States v. Glenn, 2022 U.S. Dist. LEXIS 84236 (N.D.Ohio May 5, 2022).*

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