“Here, the uncontested facts justify a protective sweep of the hotel room. Detective Holmes testified that at the time of Defendant’s arrest, there was still a suspect in the armored truck robbery at-large whose whereabouts were unknown. … As such, the arresting officers had reasonable and articulable suspicion that the hotel room harbored a dangerous individual, justifying the sweep. See Buie, 494 U.S. at 334. In so doing, the officers were permitted to search the area ‘from which an attack could be immediately launched.’ Id. Thus, evidence located in ‘plain view’ during the sweep need-not be suppressed.” United States v. Montalvo-Flores, 2021 U.S. Dist. LEXIS 77482 (D.N.J. Apr. 22, 2021).*
Ten day delay in presentment of a non-citizen arrested on the high seas was not unreasonable. United States v. Taborda-Reales, 2021 U.S. Dist. LEXIS 77416 (D.P.R. Apr. 20, 2021).
Plaintiff’s argument that the 17 year old complaining witness’s statement was unreliable and self-serving and thus didn’t show probable cause is rejected. Jackson v. Marion Police Dep’t, 2021 U.S. Dist. LEXIS 77580 (N.D. Ind. Apr. 22, 2021).*