D.Conn.: Officer had RS for a stop, but the frisk exceeded the scope of the RS

Officers had reasonable suspicion to believe that defendant was a trespasser on the apartment complex where he was stopped, but the CI’s information that he was a drug dealer was not corroborated or specific, and the pat down exceeded the purpose of the stop. United States v. Pressley, 2011 U.S. Dist. LEXIS 54096 (D. Conn. May 20, 2011).*

A truck stop employee found a quantity of heroin and cocaine in a baggie in the bathroom, and called the police. He had a description of a person who could have lost it and the car she came in. The police staked out the truck stop and, four hours later, a car arrived and a man got out and looked on the ground in the parking lot with a flashlight. He saw the police and left. The officer stopped the vehicle, and close up could see it matched the description given by the truck stop employee. The stop was with reasonable suspicion. It led to a valid search under the automobile exception. State v. Johnson, 152 Idaho 56, 266 P.3d 1161 (App. 2011).

Statutory county court judge that issued the search warrant lacked authority to issue a search warrant out of court under their enabling legislation. District court judges do have such jurisdiction under the constitution. Sanchez v. State, 2011 Tex. App. LEXIS 3824 (Tex. App.—Houston (1st Dist.) May 19, 2011).*