M.D.Fla.: Attempted flight to back of house from arrest in the home justified protective sweep

Officers entered with an arrest warrant. Defendant’s attempt to flee to the back of the house justified a protective sweep of that area because of the possibility there might be others back there. United States v. Thompson, 2017 U.S. Dist. LEXIS 55601 (M.D. Fla. April 12, 2017).

The trial court credited the officer’s testimony that defendant crossed the fog line, and that was justification for the stop. State v. Phillips, 2017-Ohio-1312, 2017 Ohio App. LEXIS 1334 (9th Dist. April 10, 2017).*

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