Consent search for weapons on defendant’s person did not permit officer to open a folded dollar bill

Arrest for disorderly conduct was unjustified, and the defendant consented to a frisk for weapons. In the watch pocket of his jeans, the officer felt what he thought was a joint, but it turned out to be a dollar bill. Opening the dollar bill exceeded the consent, even though the officer had reason to believe that the dollar bill contained crack, which it did. State v. Chauvin, 945 So. 2d 752 (La. App. 5th Cir. October 31, 2006).

Defendant had no standing to contest the search of a garbage bag of marijuana that he placed in the trunk of a friend’s car before he got in it. He had standing to challenge the stop but not the search of the bag. Valle v. State, 2006 Ga. App. LEXIS 1361 (November 2, 2006).

Officers had PC for defendant’s arrest when he called informant back and arranged a meet for a drug sale and then showed up. State v. Guillory, 945 So. 2d 798 (La. App. 3d Cir. November 2, 2006).*

Traffic stop at night led officer to window of car, and he shined his flashlight in and saw drugs in plain view. State v. Gray, 2006 La. App. LEXIS 2388 (5th Cir. October 31, 2006, released for publication January 19, 2007).*

Stop for riding bicycle at night without a headlight was justified, and defendant abandoned drugs when he was stopped. Because there was a factual basis for the stop, pretext could not be shown[, no matter how much it looked like it]. State v. Leonard, 945 So. 2d 764 (La. App. 5th Cir. October 31, 2006, released for publication January 19, 2007).