Flight from scene of a crime report is reasonable suspicion

While flight alone under Wardlow is not reasonable suspicion, it is when the flight occurs from the scene of a crime. The police arrived at the scene of a call about a bar fight, and defendant was the only person in a group to flee from the police. State v. Easley, 2007 Iowa App. LEXIS 1288 (December 12, 2007):

A suspect’s flight, in addition to his presence at the scene of a recently committed crime, provides the type of specific, articulable facts allowed under Terry to justify a brief detention by officers to resolve any ambiguity. See Terry, 392 U.S. at 21, 88 S. Ct. at 1880, 20 L. Ed. 2d at 906; see also Wardlow, 528 U.S. at 125, 120 S. Ct. at 677, 145 L. Ed. 2d at 577 (noting how Terry recognized that officers could detain individuals to resolve the ambiguity between acts that may either be innocent or criminal). Based on Easley’s behavior after seeing the officer arrive, we conclude Wertz had the reasonable suspicion necessary to justify the detention of Easley. Accordingly, we find the district court did not err in denying Easley’s motion to suppress because his constitutional rights under the Fourth Amendment were not violated.

Heck bar did not apply to an administrative search determination that favored the plaintiff and was not even attacking a conviction. Elkins v. District of Columbia, 527 F. Supp. 2d 36 (D. D.C. 2007).*

Defendant drove through headlights of patrol car parked perpendicular to road, and it was obvious that the window tint was too dark. This was cause for a stop, and the officer smelled marijuana when the window was rolled down, and that was probable cause. United States v. Ushery, 526 F. Supp. 2d 497 (M.D. Pa. 2007).*

Defendant argued that her cellphone text messages were seized without a search warrant, but the court finds consent to the seizure. United States v. Jones, 2007 U.S. Dist. LEXIS 91187 (M.D. Pa. December 12, 2007).*

Stop was based on the defendant’s car being unsafe, and the officer quickly developed probable cause, and a search incident was proper. United States v. Tolle, 2007 U.S. Dist. LEXIS 91308 (D. Or. December 6, 2007).*

State satisfied burden of proving consent in a knock and talk of a motel room. Bryant v. State, 288 Ga. App. 863, 655 S.E.2d 707 (2007).*