Defendant’s motion for new trial based on possible new evidence for litigating the search and seizure claim under F.R.Crim.P. 33 is denied because it doesn’t change the outcome. United States v. Kapahu, 2017 U.S. Dist. LEXIS 88922 (D. Haw. June 9, 2017).
An anonymous tip of defendant having a hypodermic needle was insufficient for reasonable suspicion. However, his seeing police vehicle and abruptly turning away and fiddling with things with his hands was reasonable suspicion of possession of a weapon. State v. Reno, 2017-Ohio-4326, 2017 Ohio App. LEXIS 2395 (2d Dist. June 16, 2017).*