LA: Two Rodriguez violations: car searched for weapon without RS then female officer called for a body search

Defendant was detained unreasonably without reasonable suspicion and then her car was searched for a weapon but none was found. Then the detaining officer called for a female officer to conduct a search of her person. “Because reasonable suspicion was lacking, the deputy’s announcement that a female officer was in route to perform a pat-down of defendant constituted a threat to conduct an unlawful search under the Fourth Amendment, as the deputy had no authority to do a pat-down without a warrant.” State v. Ellis, 2019 La. LEXIS 2340 (Sept. 24, 2019).

The CI wasn’t corroborated. “Although the Affidavit established CS-1’s basis of knowledge, it offered little regarding CS-1’s reliability or how the HSI agents sought to corroborate his information. It is, therefore, a close question as to whether the Affidavit established probable cause. The Court, however, need not resolve this issue because, as explained below, the fruits of the search are admissible under the good-faith exception.” United States v. Rocha-Gomez, 2019 U.S. Dist. LEXIS 165757 (S.D. N.Y. Sept. 26, 2019).*