IN: No RS for a protective sweep after def was arrested

A protective sweep of a closed room requires reasonable suspicion that an attack could be launched from the room. After defendant was arrested, there was no reasonable suspicion there was anybody else in the house; therefore, no reasonable suspicion. Johnson v. State, 2017 Ind. App. LEXIS 88 (Feb. 28, 2017).

Defendant was stopped for speeding and the defendant tossed a plastic bag from the car before he stopped. After defendant was secured, the officer walked back down the road and found the plastic bag. There was probable cause to search the car. State v. Crawford, 2017 La. LEXIS 436 (La. Feb. 24, 2017).*

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