Defendant was handcuffed as a part of his stop for officer safety and to secure the scene. They could also put him in a police car handcuffed. Finally, transporting him to the precinct for a lineup wasn’t an unreasonable seizure requiring probable cause. United States v. Carter, 2019 U.S. Dist. LEXIS 206777 (E.D. Pa. Nov. 26, 2019).
This probation search was justified by reasonable suspicion: “The officers here searched Fleming’s home only after observing him engage in what appeared to be a drug transaction in an area of Los Angeles known for illegal drug activity, recognizing him as someone with a criminal history of drug offenses, and recovering several thousand dollars in bundled cash from his vehicle. These facts satisfy the reasonable suspicion standard.” United States v. Fleming, 2019 U.S. App. LEXIS 35717 (9th Cir. Nov. 29, 2019).*
Defense counsel wasn’t ineffective for not filing a motion to suppress where defendant lacked standing. Waldron v. United States, 2019 U.S. Dist. LEXIS 206695 (D.Utah Nov. 27, 2019).*