IN: Second patdown had its own RS def was still armed

Defendant was hostile and aggressive toward officers, and a second patdown was conducted after he was handcuffed finding a gun. His actions continued and heightened concern that he had a weapon on him. J.R. v. State, 2017 Ind. App. LEXIS 799 (Dec. 8, 2017).

Officers had reasonable suspicion to detain defendant, and whether his obstruction was sufficient to charge him is a question for trial. The motion to dismiss should not have been granted. State v. Gaines, 2017-Ohio-8906, 2017 Ohio App. LEXIS 5327 (2d Dist. Dec. 8, 2017).*

Defendant was convicted of robbery, and one of the things taken was an iPhone that was tracked by “find my iPhone” to capture defendant and his co-conspirators. Despite DNA and lack of an ID from the victim, the possession of the phone and other of the victim’s propertly shortly thereafter was sufficient evidence to convict. State v. Bybee, 2017-Ohio-8869, 2017 Ohio App. LEXIS 5299 (8th Dist. Dec. 7, 2017).*

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