CA3: Protective sweep can extend to looking under a mattress because it is a common hiding place

A protective sweep can extend to looking under a mattress because it is a common hiding place. United States v. Snard, 497 Fed. Appx. 228 (3d Cir. 2012).

Officers had sufficient reason to believe that defendant was at his house and it was his based on the address in the arrest warrant confirmed by another officer. Although it was 12:30 am, there were lights on and cars in the driveway and people could be heard inside. The arrest was thus reasonable. Carpenter v. State, 974 N.E.2d 569 (Ind. App. 2012).*

Officers had a description of man fleeing from a shooting and defendant met that description, so that was reasonable suspicion. State v. Hodge, 2012 Ohio 4306, 2012 Ohio App. LEXIS 3777 (10th Dist. September 20, 2012).*

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