“The trial court erred as a matter of law in ruling that Mr. Ford’s actions did not revoke consent. An objectively reasonable officer would have understood Mr. Ford’s act of placing his hand on the outside of his pocket exactly as Officer Branson did understand it—an unequivocal withdrawal of consent to be searched.” Remanded for a separate determination of probable cause. Ford v. United States, 2021 D.C. App. LEXIS 41 (Feb. 23, 2021).
“Here, the district court determined — and neither party disputes — that the moment of arrest was when Centeno exited the Toyota Tundra and was lowered to the ground and handcuffed. At that point, the officers had in their arsenal several important pieces of information: 1) two separate civilian calls had provided the dispatch officer with similar details regarding an active shooting; 2) the dispatcher herself had overhead gunfire while on the phone with those callers; 3) the officers observed Centeno driving a vehicle that matched the description provided in the phone calls while traveling away from UEC; 4) the officers spotted Centeno close in time and place to the shooting; and, 5) when asked, Centeno told officers that he had just left the exact area of the shooting.” United States v. Centeno-González, 2021 U.S. App. LEXIS 5469 (1st Cir. Feb. 24, 2021).*