The court adopts the R&R and finds that the traffic stop was initially justified, but the officer got way off track from it into investigating other things without reasonable suspicion. Instead, the officer was investigating defendant’s criminal history for 46 minutes. The continuation of the stop was thus unreasonable. United States v. Teasley, 2023 U.S. Dist. LEXIS 48146 (W.D.N.C. Mar. 22, 2023).
The wooded area around defendant’s house was open fields, and photographs taken there did not violate the Fourth Amendment. United States v. Newbold, 2023 U.S. Dist. LEXIS 48145 (M.D.N.C. Mar. 21, 2023).*
Defendant had no standing, so there was no ineffective assistance of counsel from not filing a motion to suppress. United States v. Russell, 2023 U.S. Dist. LEXIS 48083 (W.D. La. Mar. 20, 2023).*