IL: Def had done nothing wrong; RS could not be based on reaching for pocket when officer asked for DL

Defendant’s patdown was not justified by reasonable suspicion because defendant was a random person at a gas pump, he answered the officer’s questions, did not try to flee, and reached for his pocket as the officer asked for his driver’s license [where else would it be?]. The officer’s alleged fear was not reasonable. The entire conversation prior to the patdown lasted only 15 seconds, defendant honestly admitted the possession of a gun, and the officer did not ask him if he possessed a concealed carry card prior to the frisk. Defendant was, however, a felon in possession. Reversed. People v. Flunder, 2019 IL App (1st) 171635, 2019 Ill. App. LEXIS 998 (Dec. 26, 2019).

Officer’s mistake of law about vehicles hitting the center line wasn’t reasonable because the statute wasn’t ambiguous. Thus, the stop wasn’t justified. Jones v. Commonwealth, 2019 Va. App. LEXIS 318 (Dec. 27, 2019).