Even if the officer arrests plaintiff outside the jurisdiction, state law is irrelevant under the Fourth Amendment. The search incident to the arrest was valid. Frey v. Town of Jackson, 2022 U.S. App. LEXIS 20652 (10th Cir. July 26, 2022).
Defendant says he told the officers he put the drugs in the trunk of someone else’s car, but the suppression hearing involved his denial. He doesn’t have standing under Rakas even if he did do that. United States v. Hull, 2022 U.S. Dist. LEXIS 131690 (E.D. Wash. July 25, 2022).*
Summary judgment for the defendants in a consent search case was erroneous. There is a question for trial. Jerger v. Blaize, 2022 U.S. App. LEXIS 20539 (7th Cir. July 26, 2022).*
A statutory search prohibition for the odor of marijuana was adopted after defendant’s search but before his trial. It didn’t bar the search. Montgomery v. Commonwealth, 2022 Va. App. LEXIS 317 (July 26, 2022).*