Police received a call about a man passed out in a Lexus in a parking lot with a hypodermic needle sticking in his arm and a shotgun next to him. When they got there, defendant was out of the car, got in it and drove away. They did a felony stop. There was no reasonable suspicion for the stop. Possession of the gun and the needle are not crimes. Motion to suppress granted. United States v. Lafon, 2015 U.S. Dist. LEXIS 175487 (D.Nev. Dec. 23, 2015), adopted 2016 U.S. Dist. LEXIS 10162 (D.Nev. Jan. 27, 2016).
A zoning appeal and having to pay the fees associated with it are not a Fourth Amendment seizure. Foley v. Orange County, 2016 U.S. App. LEXIS 1494 (11th Cir. Jan. 29, 2016).*