A female officer patted this male defendant down, but she did not go around the crotch area. For officer safety, a male officer followed up and did. This was reasonable, and the contraband was found by plain feel. State v. Wyatt, 2021-Ohio-3146 (12th Dist. Sept. 13, 2021).
A leg sweep is not excessive force when the arrestee continues to resist, at least for qualified immunity purposes. B.T. v. Battle, 21-10318 (11th Cir. Sept. 13, 2021).*
The use of defendant’s key to test apartment doors to find his was waived as both a search or reasonable expectation of privacy claim for failure to raise it at the district court or fully develop it even on plain error review. United States v. Wheeler, 16-3780 (3d Cir. Sept. 10, 2021).*