IL: In this forfeiture seizure, the car could not be inventoried; contents were to be returned to the owner

Officers attempted a stop of a vehicle potentially involved in an earlier occurrence. Instead of stopping, the driver fled from the stop in the car. Instead of pursuing, officers had the LPN and went to where it was registered, and it showed up a few minutes later. The car was seized for forfeiture under state law. Under that policy, the goods in the car are to be returned to the owner, not inventoried, so the inventory was invalid. Efforts to show other reasonable suspicion failed. People v. Smith, 2023 IL App (3d) 230060, 2023 Ill. App. LEXIS 377 (Oct. 19, 2023).

The district court erred in granting summary judgment for the defendant officer who shot plaintiff’s decedent while serving an order of protection. There were still disputed questions of fact for trial. Ibarra v. Lee, 2023 U.S. App. LEXIS 27895 (10th Cir. Oct. 20, 2023).*

Defendant’s guilty plea waived his Fourth Amendment claims. United States v. Leito, 2023 U.S. App. LEXIS 27941 (3d Cir. Oct. 20, 2023).*

The USDJ parts ways with the analysis of reasonable suspicion for continuing the stop, but still concludes there was, albeit a different view of the evidence. United States v. Easley, 2023 U.S. Dist. LEXIS 188693 (D. Minn. Oct. 20, 2023).*

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