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).*