A vehicle occupant making a “dipping motion” when a stop occurs like they’re putting something on the floor or under the seat, either contraband or a weapon, is reasonable suspicion. United States v. Roberts, 2018 U.S. Dist. LEXIS 161968 (E.D. N.Y. Sep. 21, 2018).
Defendant’s conduct during his traffic stop justified an arrest, and that permitted the officer to use more restraint on him. United States v. Harrison, 2018 U.S. Dist. LEXIS 161910 (W.D. Mo. Sep. 21, 2018).*