TX1: Shooting call a few minutes earlier justified protective sweep of apartment

The protective sweep of defendant’s apartment in response to a shooting call was reasonable. “The officers knew that there had been a shooting [just a few minutes earlier] and that at least one person had been shot. They did not know whether there were any suspects inside the apartment, but they had reason to believe that there might be, as they had received conflicting information from the dispatch operator and Lipscomb, who was admittedly unsure whether anyone was still inside his apartment. Because the officers’ belief was objectively reasonable, their protective sweep of Lipscomb’s apartment was lawful.” Lipscomb v. State, 2017 Tex. App. LEXIS 6185 (Tex. App. – Houston (1st Dist.) July 6, 2017).