E.D.Pa.: Protective sweep was properly limited and cell phones in plain view could be seized if it was readily apparent they were evidence

The officers’ protective sweep was justified by the facts, and it was constrained to areas large enough to hide a person. In plain view were two cell phones that were properly seized and then later searched with a warrant. United States v. Blanding, 2019 U.S. Dist. LEXIS 176133 (E.D. Pa. Oct. 10, 2019).

The gratuitous use of force on plaintiff that allegedly broke a facial bone was not entitled to qualified immunity. Alexandre v. Ortiz, 2019 U.S. App. LEXIS 30329 (11th Cir. Oct. 10, 2019).*

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