N.D.Ill.: Criminal history questions during traffic stop reasonably related to officer safety

“Officer Nisivaco’s questions about the offense for which Carson was on parole and the recency of his gun offense were permissible, ‘negligibly burdensome precautions’ taken to ensure officer safety. Rodriguez, 575 U.S. at 356.” Asking about whether he was up to date on his carry registration was also reasonable for officer safety. United States v. Carson, 2021 U.S. Dist. LEXIS 245221 (N.D.Ill. Dec. 22, 2021).

Defendant’s 2255 doesn’t show at all how defense counsel was ineffective for not filing a motion to suppress, let alone that it would be granted or would have been prejudicial to him. United States v. Ewell, 2021 U.S. Dist. LEXIS 244861 (N.D.Okla. Dec. 23, 2021).*

Defendant’s agitation during his justified traffic stop for missing a front license plate was reasonable suspicion. But the decision to tow the vehicle had already been made before the stop was allegedly unreasonably extended, so the extension doesn’t matter. United States v. Leeper, 2021 U.S. Dist. LEXIS 245057 (N.D.N.Y. Dec. 22, 2021).*

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