A frisk at 4 am in a high crime area was not only justified, it produced one round of ammunition and an empty holster by plain feel. That led to a search of the ground that produced the firearm. The frisk was valid. United States v. Johnson, 2019 U.S. App. LEXIS 11118 (11th Cir. Apr. 16, 2019) (en banc).
The trial court erred in suppressing the product of defendant’s stop for DUI because there was plenty of evidence supporting that he was in control of the vehicle and was under the influence at the time. State v. Brewer, 2019 Tenn. Crim. App. LEXIS 239 (Apr. 15, 2019).*