The officer did not have reasonable suspicion to stop and talk to defendant sitting in a car with another in a parking lot at night doing nothing. The area was considered high crime, but there was nothing suggesting any need for the officer to approach the car and direct the window be lowered. When it was rolled down, the officer smelled marijuana. Johnson v. State, 2020 Tex. App. LEXIS 4189 (Tex. App. – Houston (14th Dist.) May 28, 2020).
Defendant’s Franks motion was already denied, so it can’t form a basis for outrageous governmental conduct. United States v. Losch, 2020 U.S. Dist. LEXIS 97287 (D. Ariz. June 3, 2020).