NC: Pocket knife on car console not RS to search

Pocket knife on the console of a defendant’s car was not reasonable suspicion to search his person. State v. Duncan, 2020 N.C. App. LEXIS 525 (July 7, 2020).

Where initial stop was valid, smell of marijuana and defendant’s furtive movements were probable cause. United States v. Freeman, 2020 U.S. App. LEXIS 21383 (8th Cir. July 10, 2020).*