DC: Frisk of jacket in car was without RS

Defendant was a passenger in a rideshare, and the car was stopped for a traffic offense. They were all ordered out, and defendant took off his jacket while “blading,” said the officer, and left it in the car. The officer frisked the jacket finding a gun. The frisk of the jacket was without reasonable suspicion, and the gun should have been suppressed. Champion v. United States, 2024 D.C. App. LEXIS 2 (Jan. 4, 2024) (2-1) (argued 10/14/20 but decided 1/4/24, 3 years, 2 months, 3 weeks later; and they aren’t even embarrassed).

An inoperable headlight is reasonable suspicion for a traffic stop. State v. Kancler, 2024-Ohio-16, 2024 Ohio App. LEXIS 17 (8th Dist. Jan. 4, 2024).*

Defendant was arrested for an apparent hand-to-hand drug transaction, and he was handcuffed. His backpack was searched, too, and this was valid as an inventory because he was going to jail. United States v. Velazquez, 2024 U.S. Dist. LEXIS 1690 (D.N.J. Jan. 4, 2024).*

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