M.D.La.: A couple of pills in the car not easily identifiable as controlled substances didn’t justify a search

Defendant’s frisk was justified by reasonable suspicion. The search of his person, however, was not justified: Some pills in the car that weren’t easily identified as controlled substances does not mean that defendant was committing a crime. United States v. Richardson, 2017 U.S. Dist. LEXIS 59403 (M.D. La. April 18, 2017).

Any motion to suppress would have been meritless, so defendant did not receive IAC. United States v. Williams, 2017 U.S. Dist. LEXIS 58801 (N.D. Ind. April 17, 2017).*