The frisk of defendant did not violate the Fourth Amendment, so the trial court did not err by denying defendant’s motion to suppress the firearm. The officer encountered defendant after an unknown caller placed two 911 calls, defendant matched the physical description of the suspect at the location the caller had provided within minutes of the second call, and the officer saw defendant walking in a manner that suggested that he was concealing a firearm which justified the pat down. People v. Carter, 2019 IL App (1st) 170803, 2019 Ill. App. LEXIS 848 (Oct. 22, 2019).
Defendant’s Fourth Amendment appeal dismissed for lack of a properly presented certified question. State v. Johnson, 2019 Tenn. Crim. App. LEXIS 685 (Oct. 23, 2019).*