DTF officers entered a Greyhound bus heading to Detroit to question passengers. Defendant’s stop on the bus and then the frisk of his bag lacked reasonable suspicion. The fact there had been drug couriers on the bus before didn’t mean defendant was. The officer’s claim he didn’t know whether defendant’s backpack had a gun applied to everybody on the bus. State v. Mallory, 2020-Ohio-4848, 2020 Ohio App. LEXIS 3690 (2d Dist. Oct. 9, 2020):

“In the context of this case [and the totality of circumstances], the question before the court is whether Trooper Callister unreasonably prolonged his stop of Martinez. I conclude he did not. That the initial stop was justified is without dispute. Martinez had obscured his view of the roadway. After the stop was made, this experienced State Trooper credibly described in detail the specific circumstances that led him to believe Martinez was involved in drug trafficking, including the fact Martinez appeared nervous, did not own the vehicle he was driving so far from home, the seeming inconsistencies in his statements about whose car it was and his unusual travel plans, the nervousness he exhibited, the amount of cash he was carrying, and the fact that he was traveling along a common drug courier route to a source area. Though none of these facts by themselves could give rise to a reasonable suspicion, that is not how a reviewing court is to assess a law enforcement officer’s actions.” United States v. Martinez, 2020 U.S. Dist. LEXIS 185943 (E.D. Wis. Oct. 7, 2020).*

“Bruce insists that the officers had no reason at all to find the anonymous tip reliable, but that’s just not so. For purposes of a brief investigatory detention like the one we consider here, an anonymous 911 call giving eyewitness details of a real-time event is reliable enough ‘to credit the caller’s account.’ Navarette, 572 U.S. at 398 …” United States v. Bruce, 2020 U.S. App. LEXIS 31959 (11th Cir. Oct. 8, 2020).

“While the case is close, the officers can point to specific and articulable facts that give rise to reasonable suspicion. Alvarez matched the description of the subject who had an outstanding warrant. He was a Hispanic male, he rode a bicycle with particularly large handlebars, and he was spotted in the area where the subject was known to reside. While each of these factors individually may be insufficient to justify an investigatory stop, collectively, they are not so general as to negate reasonable suspicion.” United States v. Alvarez, 2020 U.S. Dist. LEXIS 186852 (S.D. Tex. Oct. 8, 2020).*