GA: General policy to patdown passenger when driver ordered out of vehicle violates Fourth Amendment without RS

Officer’s testimony that he routinely pats down the passenger after getting the driver out of the car was not reasonable suspicion. Here, however, defendant later consented to a search of his wallet after the patdown, and that was independent. Rogue v. State, 311 Ga. App. 421, 715 S.E.2d 814 (2011).

Defendant was prosecuted for a Mann Act violation involving underage prostitution. He was kicked out of a hotel room with the police in tow. The officers questioned the girls in the rooms and looked at their cell phones. He had no standing to question the alleged violation of the rights of the girls. United States v. Collins, 437 Fed. Appx. 760 (11th Cir. 2011).*

SVPA prisoner strip searches were shown by defense affidavit to be for legitimate penological security interests, and plaintiff has not countered that proof. Jones v. Baca, 2010 U.S. Dist. LEXIS 143589 (C.D. Cal. March 31, 2010).*