CA8 finds stop valid for grounds not relied on by Dist. Ct.

“The government defends the district court’s rationale, but argues alternatively that other facts independently provided reasonable suspicion to seize LaGrange in the restaurant parking area. We may affirm the district court’s denial of a motion to suppress on any ground supported by the record. United States v. Pratt, 355 F.3d 1119, 1121 (8th Cir. 2004). Because we conclude that the officers had reasonable suspicion to believe that LaGrange unlawfully possessed a firearm, we need not address the grounds relied on by the district court.” A firearm around drugs is enough. United States v. LaGrange, 2020 U.S. App. LEXIS 38321 (8th Cir. Dec. 9, 2020).

Defendant’s 2255 cell phone and phone records search claim was waived in his plea agreement, and it would lose on the merits anyway. It wasn’t his phone. United States v. Gordon, 2020 U.S. Dist. LEXIS 230764 (E.D. Mich. Dec. 1, 2020).*