D.P.R.: Grabbing for fannypack during traffic stop was a furtive movement justifying frisk

During a traffic stop, the defendant’s grabbing for a fannypack was a furtive movement indicating a likely weapon. United States v. Cardona-Vicente, 2013 U.S. Dist. LEXIS 185574 (D. P.R. November 18, 2013).*

“Moreover, Borbon fails to identify any evidence that law enforcement would not have recovered but for Borbon’s arrest or how the suppression of that evidence would have resulted in his acquittal.” Therefore, no Strickland prejudice. United States v. Cardenas-Borbon, 2014 U.S. Dist. LEXIS 26654 (M.D. Pa. March 3, 2014).*

2255 petitioner’s search arguments are essentially a version of the argument already made and rejected in the case, so it’s denied. United States v. Lopez, 2014 U.S. Dist. LEXIS 26648 (M.D. Pa. March 3, 2014).*

The CI’s information was adequately corroborated to show probable cause. “The defendant argues that Officer Branch was required to conduct a trash pull, perform a controlled delivery, or survey the residence to corroborate the CI’s information. However, Officer Branch was not required to perform these tasks. The record shows that the officer based the affidavit on information from multiple sources, not just the CI’s information.” United States v. Williams, 2014 U.S. Dist. LEXIS 26774 (D. Neb. March 3, 2014),* R&R 2014 U.S. Dist. LEXIS 26757 (D. Neb. January 13, 2014).*