The officer approached defendant’s vehicle pursuant to a 911 call to request a welfare check on the driver, but he did not have particularized suspicion to conduct a DUI investigation at the time he was assured defendant was not in peril or in need of assistance. City of Missoula v. Metz, 2019 MT 264, 2019 Mont. LEXIS 740 (Nov. 5, 2019).
The search warrant for defendant’s property was justified from observations from a protective sweep or a parole officer’s search. United States v. Wingrove, 2019 U.S. Dist. LEXIS 191764 (S.D. W.Va. Nov. 5, 2019).*