ID: Officer telling defendant to set aside because he was looking for a man with a warrant was not a seizure

When the officer came to defendant’s house, he said he was looking for another person, and asked defendant to move back. A reasonable person in his position would not have felt free to leave. Thus, when defendant was confronted outside the apartment, this was consensual. To the officer, defendant was acting like a lookout. Defendant was finally frisked, and the officer had reasonable suspicion because of defendant’s nervousness, knowledge of the person being sought, his own drug activity, and admission he had a knife. State v. Gottardi, 2016 Ida. App. LEXIS 104 (Sept. 1, 2016).*

The search of the juvenile’s bookbag was justified by the automobile exception and his flight. In re L.S., 2016-Ohio-5582, 2016 Ohio App. LEXIS 3483 (Aug. 31, 2016).*

District Court did not err in not suppressing all text messages off a phone seized two years earlier and held in the evidence locker. Some were suppressed, and the district court expressed its disappointment in the government’s delay. At any rate, the information seized was harmless error. United States v. Green, 2016 U.S. App. LEXIS 16083 (8th Cir. Aug. 31, 2016).*