On Point blog, page 1 of 1

COA holds that driver’s odor of alcohol and prior conviction for OWI provides reasonable suspicion to extend traffic stop

State v. Peter Joseph Idell, 2024AP2230, District I, 6/17/25 (one-judge decision; ineligible for publication); case activity

The COA holds that an odor of intoxicants and the driver’s 2009 conviction for OWI established reasonable suspicion to extend stop for expired license plates to investigate OWI.

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COA: Inevitable discovery via inventory search applies even if search occurred before decision to tow.

State v. Carter Nelson, 2024AP617-CR, 11/6/24, District II (one judge decision; not eligible for publication); case activity

The Court of Appeals reversed the circuit court’s order granting Carter Nelson’s motion to suppress cocaine seized from his vehicle without a warrant and without probable cause.  The Court held that the evidence would have inevitably been discovered in a standard inventory search when Nelson’s vehicle was towed.

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