“The officer’s order to step out of the vehicle and his directive to stand by the patrol car were reasonable under the Fourth Amendment. See Pennsylvania v. Mimms, 434 U.S. 106, 109-11 (1977) (per curiam). The officer lawfully initiated the traffic stop because Lugo was driving erratically and changed lanes without signaling. After ‘police ha[d] already lawfully decided that the driver shall be briefly detained’ in a traffic stop, the order to exit the truck was a ‘de minimis’ intrusion on his liberty justified to ensure officer safety. Id. at 111. Lugo had not pulled over very far onto the shoulder, so the officer standing on the driver’s side of the vehicle faced a ‘hazard of accidental injury from passing traffic.’ Id.” United States v. Lugo, 2021 U.S. App. LEXIS 18992 (9th Cir. June 25, 2021).
Petitioner sought coram nobis for alleged recent discovery of forged search warrant papers. “The Petitioner’s claims of newly discovered evidence are unconvincing. The Petitioner’s challenges relate to alleged inconsistencies or deficiencies in various witnesses’ trial testimony and the lack of probable cause in the search warrant affidavit. These do not amount to newly discovered evidence or unknown facts occurring after the Petitioner’s trial had concluded.” Aguilar v. State, 2021 Tenn. Crim. App. LEXIS 282 (June 25, 2021).*