MD: Two men talking at a car idling in a parking lot in a high-crime residential area at 11:30 pm wasn’t RS

Two men talking with another in a car in a high crime area at 11:30 pm in parking lot in a residential area was not reasonable suspicion. One of the men reached into the car, but there’s no way of telling that this was a hand-to-hand transaction. Moreover, the officer saw a bulge that he said he suspected was a gun, but he didn’t frisk there first. He found marijuana. No reasonable suspicion for the stop. Eppes v. State, 2022 Md. App. LEXIS 786 (Oct. 28, 2022).*

There was reasonable suspicion for a traffic stop for crossing the center line and then reasonable suspicion based on the officer’s knowledge of the defendant and his activities from a CI he’d had for years. United States v. Mack, 2022 U.S. Dist. LEXIS 196001 (N.D.W.Va. Oct. 27, 2022).*

“Although the body camera footage of Long’s arrest does not capture Saunders’ verbal consent to search the apartment, sufficient undisputed evidence demonstrates that she did validly give consent.” United States v. Long, 2022 U.S. Dist. LEXIS 196754 (E.D. Va. Oct. 28, 2022).*

Officers had reasonable suspicion to extend defendant’s stop. There was also information by collective knowledge of officers. United States v. Casares, 2022 U.S. Dist. LEXIS 196889 (E.D. Mich. Oct. 29, 2022).*

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