NC: Flipping off officer not disorderly conduct; stop suppressed

Flipping off the officer wasn’t disorderly conduct justifying the stop. The community caretaking function also does not apply. State v. Ellis, 2020 N.C. LEXIS 363 (May 1, 2020).

The state could not show that defendant’s statements were inevitably discovered from her illegal stop and search. State v. Bills, 2020 Ida. App. LEXIS 36 (Apr. 30, 2020).

The officer here was dealing with an arguing couple outside a restaurant, although it was not that heated or potentially dangerous. In “trying to help” he opened a camper shell on their pickup truck and saw evidence of a crime. The community caretaking function did not apply. United States v. Neugin, 2020 U.S. App. LEXIS 14008 (10th Cir. May 1, 2020).

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