

Smell of Marijuana, Traffic-Stop Timing, and Frisks: Fourth Circuit Upholds Gun Seizure
United States v. Carson, No. 25-4200 (4th Cir. July 8, 2026) TL;DR Police stopped a vehicle because the driver had a suspended license. Within seconds of arriving, another officer smelled marijuana coming from the vehicle and then observed a digital scale with white residue inside. Officers searched the vehicle and ordered the occupants out. One passenger, Jermaine Carson, was frisked. During the frisk, Carson told the officer he had a gun, and officers recovered a loaded Glo
8 min read


Your Phone at the Border: Fourth Circuit Says Manual Searches Require No Suspicion
United States v. Belmonte Cardozo, No. 25-4239 (4th Cir. July 13, 2026) TL;DR A traveler arriving at Washington Dulles International Airport from Bolivia was stopped for a customs inspection. A CBP officer asked him to unlock two iPhones. He complied. The officer manually opened the photo galleries, navigated to the phones’ hidden-photo folders, and discovered illegal images within approximately two minutes. The defendant moved to suppress, arguing that the significant privac
6 min read


The Stop Behind the Stop: Eighth Circuit Upholds Narcotics Investigation Built Around a Pretext Traffic Stop
United States v. Drayton, No. 24-2519 (8th Cir. July 13, 2026) TL;DR Police investigating a suspected methamphetamine trafficker watched him engage in what appeared to be multiple drug transactions throughout the day. Later, officers saw another person place a bag into his vehicle. An officer involved in the surveillance followed the suspect onto the interstate, observed him hit the fog line three times, and initiated a traffic stop. While the stopping officer was still proce
8 min read


