D.Alaska: Seizure of syringe during Terry frisk was reasonable

Seizure of a syringe from defendant’s pocket in a Terry frisk was reasonable even though it could have been a pen. Other things, no. United States v. Endsley, 2023 U.S. Dist. LEXIS 166997 (D. Alaska Sep. 20, 2023).

Plaintiff sued over a search that alleged a lack of probable cause. A state codefendant’s conviction was reversed for sufficiency of the evidence and a jury instruction error. Her claim was barred by the statute of limitations. Reguli v. Russ, 2023 U.S. Dist. LEXIS 166288 (M.D. Tenn. Sep. 19, 2023).*

“While the Government urges the Court to make a finding that Defendant was evasive, armed, and dangerous, such a finding is not necessary to conclude that Lt. Carvajal properly demanded and subsequently removed Defendant from the vehicle. Lt. Carvajal was permitted to require Defendant to exit the vehicle as a matter of course.” United States v. Angrand, 2023 U.S. Dist. LEXIS 166538 (S.D. Fla. Aug. 29, 2023),* adopted, 2023 U.S. Dist. LEXIS 166538 (S.D. Fla. Aug. 29, 2023).*

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