The officer had reasonable suspicion that defendant was armed, and he attempted to perform a frisk, which defendant refused. This led to a warrantless strip search which was justified by the Fourth Amendment exigency exception and by state statute and rule. State v. Brown, 2018 N.J. Super. LEXIS 143 (Oct. 17, 2018).
Defendant was on probation and the state requirement was reasonable suspicion for a violation of conditions for a search. Officers received information that defendant had a firearm in his house, and he kept it in his daughter’s room, unbeknownst to her. When officers came for a compliance check, the search of his daughter’s backpack in her room was reasonable. United States v. McGuire, 2018 U.S. Dist. LEXIS 178652 (D. Utah Oct. 18, 2018).*