“‘[T]he proper inquiry is not whether a traffic violation actually occurred, but rather whether there are facts presented that would lead a reasonable officer to believe that a violation may have occurred.’ … ‘This standard is not particularly rigorous, as no traffic law need actually have been broken, nor does the stopping officer have to be correct regarding the facts.” Calling an officer for back up to conduct a consent search where it hadn’t yet been sought extended the stop. “After determining the Rodriguez moment, the Court turns to whether Trooper Urban had reasonable suspicion of criminal activity to justify extending the traffic stop. The Court’s review of Trooper Urban’s testimony, the MVR, and other evidence shows that Trooper Urban has pointed to a sufficient number of facts that, when taken together, are enough to establish a reasonable, articulable suspicion of criminal activity to justify the extended traffic stop.” United States v. Washington, 2021 U.S. Dist. LEXIS 77876 (M.D. Pa. Apr. 22, 2021).
The body camera video doesn’t support the officers’ contentions that plaintiff’s decedent was resisting. Estate of Aguirre v. City of San Antonio, 2021 U.S. App. LEXIS 11975 (5th Cir. Apr. 22, 2021).*
Defense counsel’s failure to include in the record additional video clips did not prejudice the defendant and wouldn’t form the basis for his ineffective assistance claim. State v. Spencer, 2021 Del. Super. LEXIS 332 (Apr. 22, 2021).*