NC: Driving at normal speed out of a parking lot wasn’t “flight” for RS purposes

Driving out of a parking lot at a normal speed was not flight for reasonable suspicion purposes. “In the present case, the officers observed activity which made them suspect that Defendant’s actions in leaving the apartment complex might constitute flight, and then this suspicion of flight was used in turn to support the suspicion that criminal activity was afoot.” State v. Goins, 2016 N.C. App. LEXIS 713 (July 5, 2016).

Police don’t need reasonable suspicion to conduct a knock-and-talk. The information they had was likely reasonable suspicion anyway. When the door was opened and marijuana could be smelled, that justified stepping into the door because their report was drug dealing, not mere usage. United States v. Perry, 2016 U.S. Dist. LEXIS 84964 (E.D.Pa. June 27, 2016).*

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