Defendant was stopped on an “investigative alert,” which would have been sufficient if there was reasonable suspicion under the collective knowledge doctrine. There was no showing of the basis for the alert, and the stop was thus without reasonable suspicion and unreasonable. People v. Jones, 2015 IL App (1st) 142997, 2015 Ill. App. LEXIS 907 (Dec. 8, 2015).
Plaintiff was picked up on a mental commitment order, held briefly, evaluated, and released. Defendant initiated that order. A mere violation of the state mental commitment statute does not state a Fourth Amendment claim. Plaintiff’s case doesn’t even spell out an unreasonable seizure claim. Durand v. Harpold, 14-2244 (1st Cir. Dec. 7, 2015).*
Even if there was constitutional error and ineffective assistance of counsel in admission of a urine test at petitioner’s trial, it was harmless error at worse. IAC prejudice subsumes a harmless error analysis. Brown v. Aud, 2015 U.S. Dist. LEXIS 163926 (E.D.Mich. Dec. 8, 2015).*