There was probable cause for a search of defendant’s person, but there’s no evidence of exigency to justify it. A frisk produced no weapons, a drug dog didn’t alert on the car. Ultimately, he was made to empty his pockets, and there were drugs in a folded piece of paper next to cash. State v. Morgan, 2019 Tenn. Crim. App. LEXIS 445 (July 25, 2019).
Defendant didn’t stop his car immediately and drove two miles before pulling over where he didn’t speed up or evade. There was no evidence that defendant was a threat to the officer to justify a frisk. There also wasn’t any probable cause for a search. State v. Martinez, 2019 N.M. App. LEXIS 91 (July 25, 2019).*