“[T]he air freshener in a non-smoking rental car was an early and legitimate basis for suspicion to be aroused. In general, the use of air fresheners is a recognized factor contributing to reasonable suspicion.” United States v. Hawari-Rasulullah, 2022 U.S. Dist. LEXIS 145808 (M.D. Pa. Aug. 15, 2022).
Police getting an arrest warrant further in time from the event than they could have is irrelevant. United States v. Smallwood, 2022 U.S. Dist. LEXIS 146055 (E.D. Tenn. July 15, 2022).
This case started with an arrest without probable cause and a search incident, and it devolved from there. All suppressed. United States v. Miller, 2022 U.S. Dist. LEXIS 146316 (S.D. W. Va. Aug. 15, 2022).*
“Sedlak cannot show that his underlying Fourth Amendment claim was meritorious for purposes of a COA because the case law he references is distinguishable and does not create a debatable claim as to Strickland prejudice. … Consequently, Sedlak cannot show that counsel was ineffective.” Sedlak v. United States, 2022 U.S. App. LEXIS 22783 (11th Cir. Aug. 16, 2022).*