OH10: Citizen informant’s complaint of def flashing gun from car justifies frisk of person and car

A citizen informant’s complaint defendant flashed a gun was justification for both a patdown and a protective weapons search of his car. State v. Shalash, 2021-Ohio-1034, 2021 Ohio App. LEXIS 1043 (10th Dist. Mar. 30, 2021).

Calling for a drug dog within a couple of minutes of a stop for a vehicle sniff was reasonable where the stop was completed within the time normally required for the officer to write a traffic ticket. State v. Miles, 2021-Ohio-1029, 2021 Ohio App. LEXIS 1049 (5th Dist. Mar. 29, 2021).

Touching the fog line justifies a stop as the court reads the statute. Soucie v. Comm’r of Pub. Safety, 2021 Minn. App. LEXIS 200 (Mar. 29, 2021).*

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