In a post-conviction case, Riley wouldn’t be applied retroactively by statute to defendant’s cell phone search incident legal before it was decided. Sayles v. State, 2019 Tenn. Crim. App. LEXIS 193 (Mar. 28, 2019).
The stop was based on a traffic offense, and defendant’s actions were somewhat unusual [almost rising to reasonable suspicion, but the court doesn’t decide it]. The officer ran a drug dog around the car while waiting for dispatch to confirm the VIN of the car [and why was that necessary?]. His Terry frisk was justified and reasonable. State v. Brown, 2019-Ohio-1112, 2019 Ohio App. LEXIS 1172 (4th Dist. Mar. 28, 2019).*