There was no reasonable suspicion for defendant’s seizure on the totality. But, “Sierra-Ayala’s intervening volitional act, in the absence of exploitative behavior by López-Maysonet, renders the discovery of the drugs sufficiently attenuated so as to dissipate the taint of the initial unlawful seizure. Hence, we affirm the district court’s denial of Sierra-Ayala’s motion to suppress.” United States v. Sierra-Ayala, 2022 U.S. App. LEXIS 18432 (1st Cir. July 5, 2022).
Pre-Carpenter CSLI was not excludable. The trial here started when Carpenter was decided. United States v. Bailey, 2022 U.S. App. LEXIS 18441 (6th Cir. July 5, 2022).
The vehicle search here was justified both by the inventory and automobile exceptions. United States v. Trevino, 2022 U.S. Dist. LEXIS 117469 (W.D. Tex. July 5, 2022).*