W.D.N.Y.: The stairwell of a hotel was a public place for arrest purposes

The government had detailed facts connecting defendant to a bank robbery and traced his movements, some with surveillance video. This was probable cause, and his arrest was in a public place, the stairwell in a hotel. United States v. Peeples, 2017 U.S. Dist. LEXIS 215922 (W.D. N.Y. Dec. 4, 2017).*

“As long as the stop is lawful in its inception, ‘an officer is entitled to some chance to gain his bearings and to acquire a fair understanding of the surrounding scene. Just as the officer may ask for the identification of the driver of a lawfully stopped vehicle …, so he may request identification of the passengers also lawfully stopped.’” United States v. Soriano-Jarquin, 492 F.3d 495, 500 (4th Cir. 2007). This did not unlawfully extend the stop. United States v. Parks, 2018 U.S. Dist. LEXIS 9911 (W.D. N.C. Jan. 22, 2018).*