Parole officers had probable cause to believe that defendant was living at an unauthorized address after staking it out and seeing her there. They took her inside, and the entry was valid under the Fourth Amendment as a parole search. United States v. Payne, 2013 U.S. Dist. LEXIS 108256 (S.D. Ohio August 1, 2013).
“Luedtke and Goodwin originally moved to suppress any evidence seized pursuant to a search warrant or warrantless search. However, Luedtke and Goodwin never identified any seized evidence, search warrants, or warrantless searches, nor did Luedtke or Goodwin submit any legal argument for suppression. The Court therefore recommends that the motions to suppress evidence be denied as moot.” United States v. Luedtke, 2013 U.S. Dist. LEXIS 107499 (D. Minn. June 5, 2013).*
The smell of burning marijuana coming from defendant’s car made it reasonable to slightly extend the stop and then ask for consent to search. Rogers v. State, 2013 Ga. App. LEXIS 698 (July 31, 2013).*
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