E.D.Mich.: Def’s furtive movement justified extending the stop

Defendant’s reaching out of sight during a traffic stop was a furtive movement justifying extending the stop and seeing what he was doing. United States v. Edwards, 2019 U.S. Dist. LEXIS 185987 (E.D. Mich. Oct. 28, 2019).*

The protective sweep revealed only a small amount of marijuana in the bathroom, and they did not find a more substantial quantity of harder drugs hidden later found with a search warrant. There thus was an independent source. United States v. Melancon, 2019 U.S. Dist. LEXIS 186090 (E.D. La. Oct. 28, 2019).*

Defendant’s 2255 search claim has already been litigated on direct appeal, and it can’t be relitigated. United States v. Wade, 2019 U.S. Dist. LEXIS 185219 (N.D. Cal. Oct. 24, 2019).*

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