W.D.Mo.: Search incident permitted for offense of walking in the street at night

Search incident for walking in the street instead of on the sidewalk was permissible and that produced keys. Alternatively, officers had reasonable suspicion for a “protective patdown” based on other factors. United States v. Cunningham, 2019 U.S. Dist. LEXIS 164331 (W.D. Mo. Aug. 14, 2019).* [How are keys evidence of walking in the street? Was that a custodial arrest offense?]

The CI made a controlled buy with a motive to help himself in his own cases. Sufficient reliability shown for probable cause. United States v. Roberts, 2019 U.S. Dist. LEXIS 164333 (E.D. Mo. Sept. 5, 2019),* adopted, 2019 U.S. Dist. LEXIS 162985 (E.D. Mo. Sept. 24, 2019).*

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