M.D.Pa.: Refusal to show hands when ordered shows no seizure

Defendant’s refusal to show his hands when ordered to by the officer was not a seizure. United States v. Garner, 2023 U.S. Dist. LEXIS 5400 (M.D. Pa. Jan. 11, 2023).*

Defendant’s stop was justified and it escalated to reasonable suspicion within 30 seconds because of his actions and the circumstances. United States v. Simmons, 2023 U.S. Dist. LEXIS 5401 (M.D. Pa. Jan. 11, 2023).*

A dog sniff at an apartment door violated no reasonable expectation of privacy. That was settled in this circuit in 2022. “The Court finds that the corroborated information established that the CI was providing reliable information, and, in light of the totality of the circumstances described in the affidavit, the Court concludes that the information from the CI added to, rather than detracted from, the CI’s reliability and therefore also added to probable cause.” United States v. Navarrete-Rivera, 2022 U.S. Dist. LEXIS 235214 (D. Minn. Nov. 21, 2022).*

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