E.D.Pa.: Pushing shopping cart at night with an ATM in it was RS

Defendants having an ATM machine in a shopping cart late at night during a BLM “disturbance” was reasonable suspicion. United States v. Pennycooke, 2021 U.S. Dist. LEXIS 132128 (E.D. Pa. July 15, 2021).*

Since defendant concedes there was probable cause for this stop, the dog sniff was reasonable. United States v. Munoz, 2021 U.S. Dist. LEXIS 131965 (E.D. Ky. July 14, 2021).*

Defendant’s fanny pack across his chest looked too heavy and was stretched. The officers testified credibly they couldn’t see the L-shape of a gun, but they could see what had to be the slide. “Officer Rios and Sergeant Counihan also noticed the unusual bulge and the weight of the item in the fanny pack and that it was being worn in an unusual manner, although neither alerted to a horizontal rigid line as had Officer Migliaccio. … Officer Migliaccio also noticed that Hagood was wearing blue—which he recognized as a color sometimes worn by rival gangs of the Bloods.” United States v. Hagood, 2021 U.S. Dist. LEXIS 132085 (S.D.N.Y. July 15, 2021).*

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