A paramedic kept defendant from driving after an accident because defendant was too impaired to drive. That was not a government seizure, even if the paramedic was a state actor. State v. Cruz, 2023-Ohio-794, 2023 Ohio App. LEXIS 760 (5th Dist. Mar. 14, 2023).
Plaintiff lawyer didn’t state a § 1983 and Fourth Amendment claim against the State Bar for not summarily dismissing a bar complaint filed against him. They have Eleventh Amendment and prosecutorial immunity. Livingston v. N.C. State Bar, 2023 U.S. Dist. LEXIS 42353 (E.D.N.C. Jan. 30, 2023),* adopted, 2023 U.S. Dist. LEXIS 41292 (E.D.N.C. Mar. 13, 2023).*
Defendant was stopped for making terroristic threats against a hospital. When officers looked in the windows, there was an empty holster. That led to the conclusion there was a gun in the car. United States v. Wierenga, 2023 U.S. Dist. LEXIS 42864 (D.N.D. Mar. 14, 2023),*