W.D.La.: Govt showed justification for protective sweep of person then car

“The firearms and drugs were found during the protective sweep of the passenger area of the vehicle. The initial stop and pat-down of Defendant were justified under Terry, and the subsequent protective sweep of the car for weapons was a valid ‘Terry pat-down of the car.’” United States v. Collins, 2021 U.S. Dist. LEXIS 56382 (W.D. La. Mar. 2, 2021)

A city ordinance required employers to grant sick leave and submit to administrative subpoenas to enforce it without any review. Plaintiffs sued. The ordinance was amended to require review for enforcement. The city rendered this Fourth Amendment claim moot. ESI/Employee Solutions LP v. City of Dallas, 2021 U.S. Dist. LEXIS 56595 (N.D. Tex. Mar. 25, 2021).*

Defendant fails in his Franks proffer to show that the misstatements in the affidavit were intentional or with reckless disregard. United States v. Morrow, 2021 U.S. Dist. LEXIS 56833 (D. Nev. Mar. 25, 2021).*

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