The juvenile in this case was in a Kroger parking lot late one Sunday morning asking to use cell phones. The police were called, and he was found with two backpacks and the police suspected he was a runaway. A patdown was not shown by the state to be objectively for officer safety. K.G. v. State, 2017 Ind. App. LEXIS 317 (July 31, 2017).
There was probable cause for issuance of the search warrant here independent of the protective sweep defendant alleges was unreasonable. Brown v. Commonwealth, 2017 Va. App. LEXIS 184 (Aug. 1, 2017).*