Lack of nexus between drugs and the defendant is an evidentiary question for trial, not a motion to suppress. The search is legal in any event. United States v. Cunningham, 2023 U.S. Dist. LEXIS 43510 (D.S.C. Mar. 14, 2023).
The burn pit on defendant’s property was outside the curtilage in open fields. This court has no authority to overrule the open fields doctrine. Auld v. State, 2023 Tex. App. LEXIS 1647 (Tex. App. – San Antonio Mar. 15, 2023).*
The officer’s contact with defendant at a McDonald’s wasn’t a seizure until the officer determined he was under the influence. State v. True, 324 Or. App. 621 (Mar. 15, 2023)* (under submission for 22 months).