The following excerpt is from United States v. Pascual, No. 11-2988-cr (2nd Cir. 2012):
4. See United States v. Gaines, 457 F.3d 238, 244 (2d Cir. 2006) (remanding where district court made "anomalous and incomplete" factfindings); United States v. Pena, 961 F.2d 333, 337 (2d Cir. 1992) (remanding where record did not allow the panel to determine whether the defendant had a reasonable expectation of privacy in the car being searched); United States v. Gorski, 852 F.2d 692, 696 (2d Cir. 1988) (remanding where there was no evidence that it was inevitable that an inventory search would be conducted).
5. See United States v. Matsushita, 794 F.2d 46, 49 (2d Cir. 1986) (remanding where it was unclear whether the district court's probable cause finding referred to the initial seizure or the defendant's eventual arrest at the police station).
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