Defendant was arrested for drug offenses, and a jailer told him “he needed ‘to submit to a UA.’ As Jennings was getting the cup for the urine sample out, and without any Miranda advisement, Brown said, ‘My piss is going to melt right through that cup.’ ... Brown provided a sample and it tested positive for methamphetamine, amphetamine and cannabinoids.” The UA was valid as a search incident. United States v. Brown, 2013 U.S. Dist. LEXIS 58791 (D. S.D. February 15, 2013):
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