CA5: Independent RS obviated govt’s reliance on collective knowledge

“First, we need not address the collective-knowledge doctrine. The police officer who initiated the traffic stop developed reasonable suspicion of a straw purchase through his own questioning and discovery of the firearm in Perez’s trunk after Perez lied about having a firearm. … [¶] Similarly, because the police officer developed an independent reasonable suspicion of a straw purchase, the officer was entitled to continue the detention for a reasonable period of time.” United States v. Perez, 2021 U.S. App. LEXIS 370 (5th Cir. Jan. 7, 2021).

There was reasonable suspicion to stop defendant for suspicion of DUI because he couldn’t keep in his lane, the area was one of bars, it was early morning hours, the area was well known for DUI arrests, and defendant signaled a turn where there was no turn. Patel v. State, 2021 Tex. App. LEXIS 65 (Tex. App. – Tyler Jan. 5, 2021.*

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