Defendant was lawfully stopped for riding his bicycle on the sidewalk over a bridge, but it was only an infraction and a search incident was unreasonable. United States v. Harris, 2020 U.S. Dist. LEXIS 145000 (E.D. Cal. Aug. 12, 2020).
Defendant was stopped for riding a bicycle at night without a light. During the stop, his body language changed and the officer could smell marijuana on defendant. That justified a frisk for officer safety. United States v. Overton, 2020 U.S. Dist. LEXIS 145276 (N.D. Tex. Aug. 12, 2020).*