Police were called to defendant’s home in a domestic call that he was holding his wife and her child against their will. They entered and handcuffed him. A patdown of his person produced ammunition. Officers looked in a stack of four tires on the patio and found two guns. Then, a telephonic search warrant was applied for. There was an independent source for issuance of the warrant because there was probable cause even without considering the finding of the firearms from the finding of ammunition and the crime of violence. United States v. Washington, 2017 U.S. App. LEXIS 11544 (9th Cir. June 28, 2017).
Defendant’s furtive movements after his vehicle was stopped by the police justified a protective search of the vehicle for weapons. State v. Watts, 2017 La. App. LEXIS 1184 (La.App. 4 Cir. June 28, 2017).*