MI: No RS for getting def out of car for a frisk

Defendant’s stop was justified, but getting him out of the vehicle for a frisk was not. Suppressed. People v. Turner, 2022 Mich. App. LEXIS 4943 (Aug. 18, 2022) (2-1).

On the totality, defendant consented to an interview in his own house. He invited the officers in, they were in plain clothes, they all shook hands, weapons weren’t drawn, and it was conversational. United States v. Woody, 2022 U.S. App. LEXIS 23133 (10th Cir. Aug. 19, 2022).*

CoA denied. Defense counsel raised the Franks claim defendant raises now, but it failed on the defense burden of proof. Thomas v. United States, 2022 U.S. App. LEXIS 23148 (6th Cir. Aug. 18, 2022).*

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