IN: dog sniff outside a hotel room door was reasonable under the state constitution

A dog sniff outside a hotel room door was reasonable under the state constitution. (And, while other information was illegally gathered, this was enough for the warrant.) Crabtree v. State, 2022 Ind. App. LEXIS 385 (Dec. 1, 2022).

Excessive force in a school is found the same as the general rule looking to T.L.O. and Graham. J.I.W. v. Dorminey, 2022 U.S. App. LEXIS 33203 (11th Cir. Dec. 1, 2022).

Defendant’s guilty plea “was a complete admission of guilt” and waived his suppression issues. State v. Kirkman, 2022-Ohio-4229, 2022 Ohio App. LEXIS 4043 (3d Dist. Nov. 28, 2022).*

“Accordingly, when Trooper Gurney learned that the registered owner of the vehicle, Simanton, had an active warrant, under Bromgard, the active warrant was enough for Trooper Gurney to stop the vehicle if it was reasonable to believe Simanton was in the vehicle. Pursuant to Glover, it was reasonable for Trooper Gurney to infer Simanton would be driving his own vehicle. As such, Trooper Gurney conducted a valid traffic stop of Simanton based on Simanton’s active warrant. The district court erred by finding there was not reasonable suspicion for the traffic stop.” State v. Simanton, 2022 Ida. App. LEXIS 19 (Dec. 1, 2022).

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