CA6: Protective sweep under a couch was reasonable

The government showed that a protective sweep under a couch was reasonably justified in looking for a person. United States v. Vanhook, 2021 U.S. App. LEXIS 17245 (6th Cir. June 10, 2021).

The contents of recorded jail telephone calls coupled with a CI’s report was probable cause for a search of defendant’s house. United States v. Stanko, 2021 U.S. Dist. LEXIS 107798 (W.D. Pa. June 9, 2021).*

Two officers on foot encountered defendant’s car. They had reasonable suspicion the occupants passed counterfeit currency. Defendant had two names and DOBs. That ripened to probable cause. Hill v. State, 2021 Ind. App. LEXIS 192 (June 9, 2021).*

Defendant’s search issue decided on appeal could not be relitigated in post-conviction. Roberson v. State, 2021 Tenn. Crim. App. LEXIS 257 (June 9, 2021).*

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