W.D.Tenn.: Summers doesn’t prohibit a search of a defendant near execution of a search warrant when there is probable cause for search of person

Summers doesn’t prohibit a search of a defendant near execution of a search warrant when there is probable cause for a search of his person. United States v. Matlock, 2014 U.S. Dist. LEXIS 181607 (W.D.Tenn. October 24, 2014).

Defendant was not seized in a parking lot when he was asked questions by an officer and consented to a patdown. He was asked a few questions and his movement was not blocked. United States v. Martin, 2015 U.S. App. LEXIS 1674 (4th Cir. February 3, 2015).*

Defendant’s stop for window tinting and obstructive vision were with probable cause, even if the officer might have been slightly mistaken as to the tinting exemptions in the state. United States v. Travis, 2015 U.S. Dist. LEXIS 12446 (D.Minn. February 3, 2015).*