E.D.Cal.: Smell of MJ still PC in a California National Park even though not under state law

The smell of marijuana from a car is no longer probable cause under California law, but it is still in a national park. United States v. Tolmosoff, 2024 U.S. Dist. LEXIS 83134 (E.D. Cal. May 7, 2024).

Defendant wasn’t seized by the officer parking by his car, but he fled and attenuation applies. United States v. Zamora, 2024 U.S. Dist. LEXIS 82489 (D. Mont. May 6, 2024).*

Defense counsel’s failure to file a reply brief on a suppression motion isn’t a showing of prejudice. Carpenter v. United States, 2024 U.S. Dist. LEXIS 82928 (N.D. Ill. May 7, 2024).*

Probable cause was based both on informant hearsay and officers watching a controlled buy. United States v. Britton, 2024 U.S. App. LEXIS 10672 (8th Cir. May 2, 2024).*

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