MO: Delay in resolving traffic stop was reasonable because of heavy radio traffic

The delay in getting basic information back on defendant was caused by heavy radio traffic at the time, and the officer didn’t unduly delay resolution of the stop. Defendant also consented. (This was reviewed under plain error for a failure to object at trial.) State v. Patterson, 2016 Mo. App. LEXIS 486 (May 10, 2016).

Defendant’s consent not having been raised or discussed in the trial court is not preserved for appeal. The stop was justified and the subsequent frisk was valid. State v. Trice, 2016 Iowa App. LEXIS 464 (May 11, 2016).

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