Defendant’s declining to interact with the officer and trying to avoid him is not reasonable suspicion because people have a right to do that. United States v. Brown, 2018 U.S. Dist. LEXIS 97602 (N.D. Ga. May 10, 2018).
Defendant abandoned cell phones, one in a car and another in a field. United States v. Antoine, 2018 U.S. Dist. LEXIS 96403 (N.D. W.Va. June 8, 2018).*