KS: Def’s stop when she was unconscious in a car was valid as a public safety stop

Defendant was unconscious in a car slumped over at the wheel at 2 am, unresponsive to a spotlight on her. This was valid as a public safety stop. State v. McKenna, 2020 Kan. App. LEXIS 7 (Jan. 31, 2020).

“A court will not find that defense counsel was ineffective for failing to file a meritless motion to suppress.” People v. McIntosh, 2020 IL App (5th) 170068, 2020 Ill. App. LEXIS 47 (Jan. 30, 2020).

This was an immigration checkpoint, and the presence of a drug dog didn’t make it purely criminal enforcement. The dog didn’t delay the process at all. United States v. Yasin, 2020 U.S. App. LEXIS 3062 (5th Cir. Jan. 30, 2020).*

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