The owner of cash in this forfeiture action showed that the stop exceeded the time necessary for writing a ticket for a seat belt violation, so he prevails in the forfeiture of his cash seized from a backpack in the trunk. In re Holloman, 2017 Del. Super. LEXIS 360 (July 24, 2017).*

The officer had reasonable suspicion to detain defendant during the traffic stop that defendant was trafficking drugs when defendant appeared overly nervous, the vehicle belonged to an absent third party, defendant said he was returning from Philadelphia, a source location for narcotics, a records check showed a lengthy criminal history for assault and drug offenses, and the officer remembered prior contact with defendant and with the same vehicle that had yielded drugs and a hypodermic needle. That reasonable suspicion permitted bringing a drug dog to the scene. Commonwealth v. Green, 2017 PA Super 244, 2017 Pa. Super. LEXIS 571 (July 25, 2017).*

While objective facts must support a frisk, an officer’s subjective beliefs are at least relevant evidence on how objective it is. “In short, an officer’s subjective fear or belief that a stopped person is armed and presently dangerous is not individually controlling on the question of reasonableness of a frisk. It is not indispensable, but it is not to be ignored.” State v. Bannon, 2017 Kan. LEXIS 396 (July 28, 2017):
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