The exit border search of defendant’s bags and computers was reasonable in this government fraud investigation. Particularized suspicion wasn’t even required, albeit present. United States v. Nkongho, 2021 U.S. Dist. LEXIS 184402 (D.Md. Sept. 27, 2021).
Plaintiff’s stop for allegedly videotaping the security features at a courthouse entrance was reasonable under all the circumstances. “As the Seventh Circuit recognized in Braun v. Baldwin, courthouses are ‘potentially dangerous places because of the presence of criminal defendants, bitterly divorcing spouses and custody-contesting ex-spouses, and other highly stressed, emotionally excited, and even violence-prone litigants,’ and thus, police and guards ‘are entitled to exercise a degree of control that would be oppressive in a different setting.’ 346 F.3d 761, 765 (7th Cir. 2003) ….” Bergquist v. Milazzo, 2021 U.S. Dist. LEXIS 184852 (N.D.Ill. Sept. 28, 2021).