MD: Michigan v. Long protective frisk of a car includes looking under floor mats

Defendant was driving in a high crime area and engaging in activity suggesting a drug transaction. When officer stopped his vehicle, he acted suspiciously and made furtive movements. The Michigan v. Long protective sweep of a car includes lifting the floor mats. Goodwin v. State, 2017 Md. App. LEXIS 1271 (Dec. 21, 2017).

A “bait car,” one left to see if it would get stolen, was, and it was found on property near defendant. Defendant never touched the car or got in it or placed anything in it or took anything out of it. He merely looked in twice. Another car arrived, and he got in it and left with the others. Stopping the car was without reasonable suspicion of criminal activity. A.M. v. State, 2017 Fla. App. LEXIS 19466 (Fla. 5th DCA Dec. 22, 2017).*

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