Defendant was arrested outside his motel room, but that did not bar a protective sweep of the motel room where the officers had reason to believe others could be present. Baldwin v. United States, 2019 U.S. Dist. LEXIS 175253 (N.D. Ind. Oct. 9, 2019).
The officer had reason to stop the defendant for abrupt lane changes where he drove across the center line and onto the shoulder. Commonwealth v. Larose, 2019 Mass. LEXIS 577 (Oct. 10, 2019).*
In defendant’s stop, the officer smelled marijuana and defendant admitted that he had some. The subsequent search was valid. Therefore, defense counsel couldn’t be ineffective for not moving to suppress. In re O.N., 2019-Ohio-4159, 2019 Ohio App. LEXIS 4238 (8th Dist. Oct. 10, 2019).*