When heroin and cash were found in the search of a car based on the smell of marijuana, seizure of a notebook was reasonable. The notebook was limited information compared to a cell phone. United States v. Pierre, 2021 U.S. Dist. LEXIS 81917 (W.D. La. Apr. 29, 2021).<\/p>\n\n\n\n
Defendant\u2019s motion to suppress PBT results didn\u2019t include the predicate probable cause issue, so it\u2019s not before the court of appeals. People v. Robe<\/a>, 2021 Mich. App. LEXIS 2716 (Mar. 18, 2021).<\/p>\n\n\n\n An open container in the back seat was reasonable suspicion for further inquiry and prolonging the stop. United States v. Patterson<\/a>, 2021 U.S. App. LEXIS 12764 (6th Cir. Apr. 27, 2021).*<\/p>\n\n\n\n Defendant didn\u2019t back up his Franks claim with an offer of proof, just an allegation. State v. Schubert<\/a>, 2021-Ohio-1478, 2021 Ohio App. LEXIS 1467 (5th Dist. Apr. 28, 2021).*<\/p>\n","protected":false},"excerpt":{"rendered":" When heroin and cash were found in the search of a car based on the smell of marijuana, seizure of a notebook was reasonable. The notebook was limited information compared to a cell phone. United States v. Pierre, 2021 U.S. … Continue reading