The officer did not immediately have probable cause to arrest defendant, but the unfolding circumstances before him ended up rising to probable cause. There was more than suspicion and more than proximity. Defendant’s furtive movements supplied more cause. Defendant’s hiding his gun in a box in the office of the 7-Eleven, that he had no right to do as a trespasser, was an abandonment, even with his professed intent to return to reclaim it. United States v. Brown, 2020 U.S. Dist. LEXIS 49419 (D. Kan. Mar. 23, 2020).
A store’s loss prevention person telling the officer the suspect coming out of the store took a hunting knife justified handcuffing defendant on the first contact. United States v. Beckjorden, 2020 U.S. Dist. LEXIS 50326 (D. Minn. Mar. 23, 2020).*