NC: Mere visitor on the premises shouldn’t have been searched without articulatable RS

Defendant was a visitor on the premises when a search warrant was executed. A full search of his person was unreasonable because there were no facts shown justifying a belief he was armed or dangerous. The dissents view would hollow out Summers. State v. Tripp, 2020 N.C. App. LEXIS 921 (Dec. 31, 2020).

The lifetime order for SBM of these non-recidivist convicted sex offenders was unreasonable based on the record. State v. Westbrook, 2020 N.C. App. LEXIS 916 (Dec. 31, 2020);* State v. White, 2020 N.C. App. LEXIS 911 (Dec. 31, 2020);* State v. Harris, 2020 N.C. App. LEXIS 957 (Dec. 31, 2020).*

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