Defendant’s friend was involved in passing counterfeit $20 bills in a casino as viewed on video. The government, however, had no reasonable suspicion that defendant was actually involved in the scheme, so his frisk was unreasonable. Defendant’s frisk was investigatory and not for protection. United States v. Hartsell, 2020 U.S. Dist. LEXIS 7223 (N.D. Ind. Jan. 7, 2020).
The court finds that an illegal search led to calling a drug dog, so the detention and sniff became unreasonable. United States v. Bradley, 2020 U.S. Dist. LEXIS 6876 (W.D. Ky. Jan. 13, 2020).*
The officer’s plain view of marijuana and paraphernalia in defendant’s car was reasonable suspicion for further detention. State v. Nolen, 2020-Ohio-118, 2020 Ohio App. LEXIS 98 (4th Dist. Jan. 8, 2020).*