The government had no evidence of violence or reason to believe that there was anybody else in the apartment to justify a protective sweep. The crime alone, suspected drug trafficking, didn’t provide it. United States v. Delgado-Pérez, 2017 U.S. App. LEXIS 15402 (1st Cir. Aug. 16, 2017).
Reasonable suspicion developed to extend the stop. E.g., defendant was driving to Kentucky but didn’t know where he was going. United States v. Clark, 2017 U.S. Dist. LEXIS 129753 (W.D. Ky. May 23, 2017),* adopted, 2017 U.S. Dist. LEXIS 128762 (W.D. Ky. Aug. 14, 2017).*
Defendant filed a motion to suppress DNA, and the government contested and requested a second DNA test. The first DNA sample was suppressed. When the defense claimed it was calling an expert witness, the government obtained a second. The propriety of the second wasn’t contested. Bernal v. United States, 2017 D.C. App. LEXIS 216 (Aug. 17, 2017).*