NY3: No-knock permitted by circumstances at scene

The warrant application and warrant did not mention no-knock, but the facts and circumstances at the scene justified it. People v. Hayward, 2023 N.Y. App. Div. LEXIS 464, 2023 NY Slip Op 00461 (3d Dept. Feb. 2, 2023).

Exigency justified a realtime CSLI ping to locate a robber shortly after the robbery. Fogg v. State, 2023 Md. App. LEXIS 69 (Jan. 31, 2023)* (unreported).

“In sum, Bell-McGrew’s attempts to access his gun during the tight-quartered, fast-moving, and physical encounter rendered Baase’s use of force reasonable. Officer Baase was not required to wait for Bell-McGrew to grip his handgun or point it at Narewski—‘the deadly threat posed by [Bell-McGrew] could have easily and quickly transformed into deadly action in a split-second.’” Cooper v. City of Columbus, 2023 U.S. App. LEXIS 2629 (6th Cir. Feb. 1, 2023).*

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