“Defendant may not retreat to the curtilage of his home to avoid arrest.” State v. Nolan, 2019 La. App. LEXIS 1085 (La. App. 3 Cir. June 12, 2019).
The smell of marijuana was justification for search of defendant’s person. A patdown produced drugs but not a weapon. United States v. Colbert, 2019 U.S. Dist. LEXIS 97070 (S.D. Ind. June 10, 2019).*