Telling defendant to stop moving his hands around while he’s sitting in a car isn’t a “seizure.” When defendant complied, the officer who stopped him could see the corner of a baggie for drugs in plain view on the console, and that was at least reasonable suspicion. United States v. Gardenhire, 2017 U.S. Dist. LEXIS 37657 (W.D. Pa. March 16, 2017).
Defendant’s communications with an undercover officer created reasonable inferences that he was collecting child pornography, and that was probable cause for a search of his house and computer. United States v. Carlisle, 2017 U.S. Dist. LEXIS 35295 (N.D. Ill. March 13, 2017),* substituted opinion, 2017 U.S. Dist. LEXIS 72507 (N.D. Ala. May 12, 2017).*
Defendant can’t raise a Fourth Amendment claim in his 2255. Besides, it was already raised earlier in the proceedings and denied. Evers v. United States, 2017 U.S. Dist. LEXIS 35933 (W.D. Tenn. March 14, 2017).*