Defendant was suspected of possession of stolen property. Police came to his rural property to talk to him where he was self-employed working on tractors in back. He had a circular driveway. From the driveway they could see the outbuildings where he worked and some large tractor tires. “Here, testimony from the officers, as well as Devries and his girlfriend, indicates the stolen property was visible from areas not within the curtilage of the house–either the driveway or the door of the house–and the officers immediately recognized the lathe and the tires as matching the descriptions of the property reported stolen.” State v. Devries, 2018 Iowa App. LEXIS 1162 (Dec. 19, 2018).
There was reasonable suspicion for defendant’s stop for being involved in an armed robbery, and that also justifiably involved officer safety and a frisk. United States v. Slater, 2018 U.S. Dist. LEXIS 211851 (W.D. Mo. Nov. 20, 2018),* adopted, 2018 U.S. Dist. LEXIS 210984 (W.D. Mo. Dec. 14, 2018).*