When a suspected crime occurs in a car in front of the passengers, it is reasonable to infer, for probable cause purposes, that they are involved, comparing Di Re (1947) and Pringle (2003). United States v. Groves, 2023 U.S. Dist. LEXIS 202599 (S.D. Ind. Nov. 13, 2023).
There was no valid basis for defense counsel to file a motion to suppress here, so he couldn’t be ineffective for not filing one. State v. Perkins, 2023 Del. Super. LEXIS 867 (Nov. 8, 2023).*
The smell of marijuana provided probable cause for the vehicle search that produced the firearm. United States v. Sanders, 2023 U.S. App. LEXIS 30040 (5th Cir. Nov. 10, 2023).*
Defendant’s stop was factually justified, so his pretext claim fails. State v. Little, 2023-Ohio-4098 (11th Dist. Nov. 13, 2023).*