Defendant’s erratic behavior during a stop was reasonable suspicion when he also refused to stop digging around in his pockets. State v. Imani, 2017-Ohio-8113, 2017 Ohio App. LEXIS 4469 (5th Dist. Oct. 5, 2017).
The trial court did not err denying defendant’s motion to suppress because exigent circumstances justified the warrantless blood draw from defendant. The blood draw arose from a serious automobile accident, the officer was delayed in pursuing the usual procedures for obtaining a valid blood draw by the need to investigate the accident, and development of suspicion that alcohol was involved may have been delayed by defendant’s act of concealing beer cans. Aponte v. Commonwealth, 2017 Va. App. LEXIS 250 (Oct. 10, 2017).*