VA: Running the serial number of a seized firearm isn’t a “search”

When defendant got out of the car, the officer could see the butt of a gun sticking from his coat pocket, so a frisk was reasonable for officer safety. Looking at the serial number and then running it to see if it was stolen was not a search. Williams v. Commonwealth, 2020 Va. App. LEXIS 14 (Jan. 14, 2020).

Reasonable suspicion here is a close call. The call was anonymous, and the officers did nothing to attempt to corroborate anything the CI said. On the totality, then, the court finds no reasonable suspicion. The stop was thus unreasonable. United States v. Norbert, 2020 U.S. Dist. LEXIS 5197 (S.D. Miss. Jan. 13, 2020).*

The inventory of defendant’s backpack was found to be literally “by the book” and happened, not at the scene as defendant contended, but at the evidence storage facility as the officers tesified. United States v. Montano, 2020 U.S. Dist. LEXIS 5588 (D. Mont. Jan. 13, 2020).*

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