CA9: 4A requires no less intrusive measures for inventory

The officers impounding defendant’s vehicle weren’t constitutionally required to allow him to contact others to take possession of the vehicle for him. United States v. Anderson, 2022 U.S. App. LEXIS 35865 (9th Cir. Dec. 29, 2022). See Metropolitan News-Enterprise Three Disparate Views Expressed by Members of a Ninth Circuit Panel in Search Case (Dec. 30, 2022).

When stopped, defendant wearing a big coat with his hands out walked behind a bulldozer. That gave justification for a frisk for weapons. Miller v. State, 2022 Ind. App. LEXIS 422 (Dec. 27, 2022).*

Plaintiff’s pretrial § 1983 case against his state case was properly denied as frivolous. Tuten v. Gause, 2022 U.S. App. LEXIS 35724 (11th Cir. Dec. 27, 2022).*

Ordering defendant out of his car while the officer had his DL in hand was not the Rodriguez moment since that’s long been permitted during traffic stops. United States v. Vazquez-Pagan, 2022 U.S. Dist. LEXIS 232096 (M.D. Pa. Dec. 27, 2022).*

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