Shaking defendant’s fanny pack to see if there was a weapon rather than opening it was reasonable as a part of stop and frisk. United States v. Elenes, 2019 U.S. App. LEXIS 33067 (9th Cir. Nov. 5, 2019).
Officers could approach the residence defendant lived in for a knock-and-talk based on information they had he dealt drugs to somebody who overdosed. They were let in by the roommate. A protective sweep was justified by hearing noises that somebody else was inside. United States v. Hancock, 2019 U.S. Dist. LEXIS 191941 (E.D. Mo. Oct. 16, 2019),* adopted, 2019 U.S. Dist. LEXIS 190778 (E.D. Mo. Nov. 4, 2019).*
On the totality of circumstances, defendant consented to the search of his car, and he wasn’t in custody at the time. State v. Genet-Morlan, 2019-Ohio-4553, 2019 Ohio App. LEXIS 4599 (9th Dist. Nov. 6, 2019).*