Defendant was arrested for drug dealing, and he was handcuffed on the ground near the car. The search of the car here was based on seeing a gun in the car in plain view, so Gant doesn’t bar the search. United States v. Biglow, 2018 U.S. Dist. LEXIS 94144 (E.D. Mich. June 5, 2018).
After a justifiable stop, the officer concluded that something was amiss between the defendant and the other man he claimed was his brother. The conversation didn’t add up, and when the other man was asked if everything was okay, the other man said yes but shook his head no. The court finds reasonable suspicion on the totality. A little later, the officer learns the other man was to be robbed. State v. Nicholson, 2018 N.C. LEXIS 435 (June 8, 2018).*