D.N.M.: Lesser intrusive means to towing and inventory not constitutionally required

Lesser intrusive means to towing and inventory are not constitutionally required under Bertine. And here, the traffic stop was legal under Glover because the driver of the unregistered vehicle was the same gender as the registered owner. United States v. Ortega, 2023 U.S. Dist. LEXIS 39499 (D.N.M. Mar. 9, 2023).

There was probable cause for search of defendant’s cell phone for photographs of firearms. Even if there wasn’t, the good faith exception applies. United States v. Willard, 2023 U.S. Dist. LEXIS 38389 (D. Minn. Mar. 8, 2023).*

There was reasonable suspicion for defendant’s stop for DUI and an FST. State v. Mets, 2023-Ohio-710 (5th Dist. Mar. 8, 2023).*

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