OH3: Handcuffing detainee for safety when officers outnumbered 4-2 was reasonable

Defendant’s vehicle stop was by an officer outside his jurisdiction, but others with jurisdiction immediately showed up. Handcuffing defendant when the officers were outnumbered 4-2 was reasonable during the stop. State v. Davis, 2020-Ohio-619, 2020 Ohio App. LEXIS 570 (3d Dist. Feb. 24, 2020).*

A successor habeas petition doesn’t lie for ineffective assistance for not pursuing a Fourth Amendment claim because it was known all along. In re Nolley, 2020 U.S. App. LEXIS 5643 (11th Cir. Feb. 24, 2020).*

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