Defendant’s furtive movements toward his car and his agitated state justified a protective frisk of the car. United States v. Vaccaro, 2017 U.S. Dist. LEXIS 205804 (E.D. Wis. Sept. 18, 2017), adopted, 2017 U.S. Dist. LEXIS 204625 (E.D. Wis. Dec. 13, 2017).
Defendant’s guilty plea waived his motion to suppress. State v. Harris, 2017-Ohio-9052, 2017 Ohio App. LEXIS 5487 (2d Dist. Dec. 15, 2017).*
Not filing a motion to suppress does not amount to ineffective assistance of counsel when there was no reasonable probability of success. State v. Levell, 2017-Ohio-9055, 2017 Ohio App. LEXIS 5491 (2d Dist. Dec. 15, 2017).*