A ShotSpotter report was specific as to a shot coming from a rooftop in the Bronx. That house was the subject of many police calls. This led to defendants being encountered by officers who discussed with them what was going on, and it led to a frisk. The report and then the encounter led to a frisk with reasonable suspicion. United States v. Diaz, 2020 U.S. Dist. LEXIS 191250 (S.D. N.Y. Oct. 14, 2020).
Petitioner won an appeal and got a remand of his Fourth Amendment claim, but the remand didn’t go well for him. Still, he had a “full and fair opportunity” to litigate his Fourth Amendment claim in the state courts. Clay v. Lawrence, 2020 U.S. Dist. LEXIS 191207 (N.D. Ill. Oct. 15, 2020).*