The specific apartment number wasn’t given, but the physical and geographic location was, and that’s sufficient. “This description provided sufficient particularity for officers to locate the unit to be searched. Accordingly, the Court finds that the affidavit’s description of the unit satisfies the Fourth Amendment’s particularity requirement.” United States v. Johnson, 2019 U.S. Dist. LEXIS 174469 (D. N.M. Oct. 8, 2019).
During an otherwise lawful traffic stop, officers saw a gun and drew their weapons on defendant. The subsequent protective search of the car was valid. United States v. Moorer, 2019 U.S. Dist. LEXIS 173828 (S.D. Ala. Oct. 7, 2019).*