GA: Patdown led to search for DL and that was unreasonable: Via FourthAmendment.com.

Defendant claimed he did not have a driver's license and gave a name. He consented to a patdown for weapons, and the officer felt a card. He demanded production of the card, and it was his DL with the real name. The production of the card was not justified under the patdown. Johnson v. State, 2009 Ga. App. LEXIS 596 (May 14, 2009).

Officer violated state law by recording conversation between two suspects in a police car, but the dog sniff of the car was permissible under inevitable discovery. State v. French, 2009 Ohio 2342, 2009 Ohio App. LEXIS 1983 (9th Dist. May 20, 2009).*

Officer had exigent circumstances for entry after responding to a call about a domestic dispute on the premises involving women. When no women came to the door to talk about it and defendant admitted that a woman was around, he had reason to enter to check on her welfare. State v. Baker, 2009 Ohio 2340, 2009 Ohio App. LEXIS 1995 (9th Dist. May 20, 2009).*

Under state judicial assignment rules, once a case was reassigned, the other judge could not rule on it. This was not a double jeopardy error, however, and the first judge's denial of the motion was reversed for reconsideration with second judge. State v. Vanni, 2009 Ohio 2295, 2009 Ohio App. LEXIS 1990 (9th Dist. May 18, 2009).*

PO had reasonable cause to conduct a probation search of defendant's premises after talking with defendant's roommate. State v. Hedgecock, 2009 Ida. App. LEXIS 60 (May 14, 2009).*

Dryer sheets found in a rental car is a likely masking device and a factor worth considering in reasonable suspicion. Feeney v. State, 2009 WY 67, 2009 Wyo. LEXIS 63 (May 21, 2009).*

Officer noticed on the defendant's rental agreement that the rental car was permitted only to operate in California and Nevada, but it was in Kansas. Defendant lied about his geographical permission, and his story otherwise was implausible. Coupled with nervousness, the officer had reasonable suspicion. United States v. Duenas, 2009 U.S. App. LEXIS 10857 (10th Cir. May 21, 2009) (unpublished).*

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