Defendant’s arrest for burglary, a violent crime, and his uncooperativeness justified a search incident of his backpack for possible weapons. People v. Mabry, 2020 NY Slip Op 03540, 2020 N.Y. App. Div. LEXIS 3583 (2d Dept. June 24, 2020).
There was probable cause for defendant’s arrest while executing a search warrant at his house. The officers said they wouldn’t arrest his girlfriend if he claimed the drugs, which he did. It wasn’t coerced. United States v. Sheppard, 2020 U.S. Dist. LEXIS 110674 (W.D. Ky. June 24, 2020).*
In lieu of appeal, the case is remanded to the trial court to require additional discovery for the defense. “Following that in camera review the circuit court shall determine whether this information regarding the dates, times, and locations of the controlled buys would be helpful to the defense.” People v. Robinson, 2020 Mich. App. LEXIS 3986 (June 24, 2020)* (apparently granting the relief of the appeal and remanding).