A protective sweep can occur after an arrest at the threshold even though defendant’s girlfriend said nobody else was there. United States v. Villanueva, 2019 U.S. Dist. LEXIS 89450 (D. S.D. May 29, 2019).
The defendant being armed when the police enter on a search warrant, but he fled out the back with his marijuana in hand leaving the gun behind still committed a crime of violence against the police under state law. People v. Calloway, 2019 IL App (1st) 160983, 2019 Ill. App. LEXIS 371 (May 29, 2019).*