Defendant’s Fourth Amendment rights were not violated when he was arrested without a warrant with probable cause in a public place. Reaching in defendant’s sweat shirt pocket to retrieve a gun was reasonable. United States v. Kelly-Sizer, 2021 U.S. Dist. LEXIS 67103 (E.D. Pa. Apr. 6, 2021).
Either of the two competing theories of defendant’s lane change violation stop provides reasonable suspicion. Dugar v. State, 2021 Tex. App. LEXIS 2626 (Tex. App. – Beaumont Apr. 6, 2021).*
The trial court denied defendant’s motion to suppress without adequate findings. The case was remanded, and the original judge had retired. The new judge also failed to make the requisite findings. Remanded again. State v. Swain, 2021-NCCOA-101, 2021 N.C. App. LEXIS 128 (Apr. 6, 2021).*