E.D.N.C.: Body camera corroborated RS for frisk

“Body camera footage corroborated the detectives’ testimony that the circumstances reasonably suggested Defendant may have been armed and that a pat-down search was needed to ensure officer safety. …. When faced with an uncooperative and seemingly agitated individual suspected of narcotics distribution, a prudent officer would remove that individual from the car and frisk his outer clothing for other weapons. … As such, the Court finds that the detention and the investigative frisk for weapons were proper.” United States v. Drakeford, 2019 U.S. Dist. LEXIS 67840 (E.D. N.C. Apr. 22, 2019);* United States v. Melvin, 2019 U.S. Dist. LEXIS 67491 (E.D. N.C. Apr. 22, 2019).*

The Playpen warrant issue here was foreclosed by United States v. McLamb, 880 F.3d 685, 686 (4th Cir.), cert.denied, 139 S. Ct. 156 (2018), applying good faith exception. United States v. Goins, 2019 U.S. App. LEXIS 11617 (4th Cir. Apr. 22, 2019).*

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